on; and while a judgment against
a corporation in one State may validly bind a stockholder in another
State to the extent of the par value of his holdings,[37] an
administrator acting under a grant of administration in one State stands
in no sort of relation of priority to an administrator of the same
estate in another State.[38] But where a judgment of dismissal was
entered in a federal court in an action against one of two joint
tortfeasors, in a State in which such a judgment would constitute an
estoppel in another action in the same State against the other
tort-feasor, such judgment is not entitled to full faith and credit in
an action brought against the other tortfeasor in another State.[39]

SERVICE ON FOREIGN CORPORATIONS

In 1856 the Court decided Lafayette Insurance Co. _v._ French et
al.,[40] a pioneer case in its general class. Here it was held that
"where a corporation chartered by the State of Indiana was allowed by a
law of Ohio to transact business in the latter State upon the condition
that service of process upon the agent of the corporation should be
considered as service upon the corporation itself, a judgment obtained
against the corporation by means of such process" ought to receive in
Indiana the same faith and credit as it was entitled to in Ohio.[41]
Later cases establish under both the Fourteenth Amendment and article
IV, section 1, that the cause of action must have arisen within the
State obtaining service in this way,[42] that service on an officer of a
corporation, not its resident agent and not present in the State in an
official capacity, will not confer jurisdiction over the
corporation;[43] that the question whether the corporation was actually
"doing business" in the State may be raised.[44] On the other hand, the
fact that the business was interstate is no objection.[45]

SERVICE ON OUT-OF-STATE OWNERS OF MOTOR VEHICLES

By analogy to the above cases, it has been held that a State may require
nonresident owners of motor vehicles to designate an official within the
State as an agent upon whom process may be served in any legal
proceedings growing out of their operation of a motor vehicle within the
State;[46] and while these cases arose under the Fourteenth Amendment
alone, unquestionably a judgment validly obtained upon this species of
service could be enforced upon the owner of a car through the courts of
his home State.

JUDGMENTS _IN REM_

In sustaining the challenge t