sition. Also it is universally agreed that a judgment may not be
impeached for alleged error or irregularity,[87] or as contrary to the
public policy of the State where recognition is sought for it under the
full faith and credit clause.[88] Previously listed cases indicate,
however, that the Court has in fact permitted local policy to determine
the merits of a judgment under the pretext of regulating
jurisdiction.[89] Thus in one case, Cole _v._ Cunningham,[90] the Court
sustained a Massachusetts court in enjoining, in connection with
insolvency proceedings instituted in that State, a Massachusetts
creditor from continuing in New York courts an action which had been
commenced there before the insolvency suit was brought. This was done on
the theory that a party within the jurisdiction of a court may be
restrained from doing something in another jurisdiction opposed to
principles of equity, it having been shown that the creditor was aware
of the debtor's embarrassed condition when the New York action was
instituted. The injunction unquestionably denied full faith and credit
and commanded the assent of only five Justices.

PENAL JUDGMENTS: TYPES ENTITLED TO RECOGNITION

Finally, the clause has been interpreted in the light of the
"incontrovertible maxim" that "the courts of no country execute the
penal laws of another."[91] In the leading case of Huntington _v._
Attrill,[92] however, the Court so narrowly defined "penal" in this
connection as to make it substantially synonymous with "criminal," and
on this basis held a judgment which had been recovered under a State
statute making the officers of a corporation who signed and recorded a
false certificate of the amount of its capital stock liable for all of
its debts, to be entitled under article IV, section 1, to recognition
and enforcement in the courts of sister States. Nor, in general, is a
judgment for taxes to be denied full faith and credit in State and
federal courts merely because it is for taxes.[93]

Recognition of Rights Based Upon Constitutions, Statutes, Common Law

THE EARLY RULE

As to the extrastate protection of rights which have not matured into
final judgments, the full faith and credit clause has never abolished
the general principle of the dominance of local policy over the rules of
comity.[94] This was stated by Justice Nelson in the Dred Scott case, as
follows: "No State, * * *, can enact laws to operate beyond its own
dominions, * * * Na