me protection upon certain classes of
defendants in local actions in which the plaintiff's claim was the
outgrowth of a relationship formed extraterritorially. But can the Court
stop at this point? If it is true, as Chief Justice Marshall once
remarked, that "the Constitution was not made for the benefit of
plaintiffs alone," so also it is true that it was not made for the
benefit of defendants alone. The day may come when the Court will
approach the question of the relation of the full faith and credit
clause to the extrastate operation of laws from the same angle as it
today views the broader question of the scope of State legislative
power. When and if this day arrives, State statutes and judicial
decisions will be given such extraterritorial operation as seems
reasonable to the Court to give them. In short, the rule of the
dominance of local policy of the forum State will be superseded by that
of judicial review.[125]

The question arises whether the application to date, not by the Court
alone but by Congress and the Court, of article IV, section 1, can be
said to have met the expectations of its framers. In the light of some
things said at the time of the framing of the clause this may be
doubted. The protest was raised against the clause that in vesting
Congress with power to declare the effect State laws should have outside
the enacting State, it enabled the new government to usurp the powers of
the States; but the objection went unheeded. The main concern of the
Convention, undoubtedly, was to render the judgments of the State courts
in civil cases effective throughout the Union. Yet even this object has
been by no means completely realized, owing to the doctrine of the Court
that before a judgment of a State court can be enforced in a sister
State, a new suit must be brought on it in the courts of the latter; and
the further doctrine that with respect to such a suit, the judgment sued
on is only evidence; the logical deduction from which proposition is
that the sister State is under no constitutional compulsion to give it a
forum. These doctrines were first clearly stated in the McElmoyle Case
and flowed directly from the new States' rights premises of the Court;
but they are no longer in harmony with the prevailing spirit of
constitutional construction nor with the needs of the times. Also, the
clause seems always to have been interpreted on the basis of the
assumption that the term "judicial proceedings" refe