City of Philadelphia v. Smith

The opinion of the Court was delivered by

SULLIVAN, J.

This appeal by defendants presents the question whether the Full Faith and Credit Clause, U.S. Const., Art. IV, § 1, requires a state to recognize that portion of a sister state’s money judgment representing a civil penalty for unpaid taxes. Our conclusion is that such recognition must be given.

Defendants are New Jersey residents employed by the federal government on the naval base in Philadelphia. They are subject to the Philadelphia Wage and Net Profits Tax Ordinance (City Code § 19-508), but failed to pay the tax due under the ordinance.…