had reported in 1781: After several further modifications, the Full Faith and Credit Clause assumed the form in which it remains today. James Wilson said during the constitutional convention that, if Congress were to not use its power under the latter part of this clause, then the former part of this clause "would amount to nothing more than what now takes place among all Independent Nations". Later, during the ratification process, James Madison remarked further on this subject, in Federalist No. 42. He wrote that the corresponding clause in the Articles of Confederation was "extremely indeterminate, and can be of little importance under any interpretation which it will bear". Of the expanded clause in the Constitution, Madison wrote that it established a power that "may be rendered a very convenient instrument of justice, and be particularly beneficial on the borders of contiguous States." Interpretation In 1790, shortly after the Constitution had been ratified, Congress took action under the Full Faith and Credit Clause, enacting that "the records and judicial proceedings, authenticated as aforesaid, shall have such faith and credit given to them in every Court within the United States, as they have by law or usage in the Courts of the state from whence the said records are or shall be taken." In 1813, the Supreme Court interpreted this federal statute, in the leading case of Mills v. Duryee, where the judgment of a New York court was used in a local District of Columbia court. Justice Joseph Story wrote for the Court that it was the federal statute (rather than the constitutional provision) that made records from one state effective in another state: Although the Court was engaged in statutory interpretation in Mills, the Court eventually characterized Mills as a constitutional decision, in the 1887 case of Chicago & Alton v. Wiggins. During the following decades and centuries, the Supreme Court has recognized a "public policy exception" to both the Full Faith and Credit Clause and the accompanying federal statute. In 1939, the Court in Pacific Employers Insurance v. Industrial Accident wrote: [T]here are some limitations upon the extent to which a state may be required by the full faith and credit clause to enforce even the judgment of another state in contravention of its own statutes or policy. See Wisconsin v. Pelican Insurance Co., 127 U.S. 265; Huntington v. Attrill, 146 U.S. 657; Finney v. Guy, 189 U.S.