Note 49 — ARTICLE IV

See also Simmons v. Saul, 138 U.S. 439, 448 (1891). In other words, the challenge to jurisdiction is treated as equivalent to the plea nul tiel record, a plea which was recognized even in Mills v. Duryee as always available against an attempted invocation of the full faith and credit clause. What is not pointed out by the Court, is that it was also assumed in the earlier case that such a plea could always be rebutted by producing a transcript, properly authenticated in accordance with the act of Congress, of the judgment in the original case. See also Brown v. Fletcher, 210 U.S. 82 (1908); German Savings Society v. Dormitzer, 192 U.S. 125, 128 (1904); Grover & Sewing-Mach. Co. v. Radcliffe, 137 U.S. 287, 294 (1890).