It is one of the first principles of law that a government should protect its own citizens, and no court will apply any law, in the determination of a suit before it, which will work an injustice to the citizens of the forum. For this exception to apply there must be an injustice to such citizens, and mere loss to such citizen is not a sufficient basis upon which to rest this exception. In Woodward vs. Brooks,4 the Supreme Court of Illinois said:

"As a voluntary foreign assignment, valid in the State where made, is enforced in this State as a matter of comity, our courts will not enforce it to the prejudice of our citizens who may have demands against the assignor. It is contrary to the policy of our laws to allow the property or funds of a non-resident debtor to be withdrawn from this State before his creditors residing here have been paid, and thus compel them to seek redress in a foreign jurisdiction; so it was held in Heyer vs. Alexander, 108 111., 385, that a voluntary assignment of a non-resident debtor's property, valid under the laws of the State where made, will not be enforced here as against domestic attaching creditors. See Chaffee vs. Fourth National Bank, 71 Me., 524; Kelley vs. Crap, 45 N. Y., 46; Johnson vs. Parker, 4

4 128 111., 222.

Bush., 149; Chicago, Milwaukee & St. Paul Railway Co. vs. Keokuk Northern Line Packet Co., 108 111., 317; Life Association of North America vs. Fassett, 102 id., 315.

"In May vs. First National Bank of Attleboro, 122 111., 551, we held that a voluntary assignment made in another State by a non-resident there, executed in conformity with our laws in respect to the conveyance of property, but inconsistent, in substantial respects, with our statute relating to assignments, will not be enforced here to the detriment of our citizens; but for all other purposes, and between citizens of the State where the assignment was made, if valid by the lex loci, it will be carried into effect by the courts of this State. That case is decisive of the one at bar. In the present case there are no domestic creditors to be affected. The attaching creditors are resident in the same State with the assignor and where the assignment was made and will be executed. As before seen, the assignment is valid under the laws of Pennsylvania, and capable of being enforced there, and under the doctrine announced, the courts of this State will give it effect as against citizens of Pennsylvania. The heirs of Miller are not complaining here. It seems that they, as well as the assignee, assignors and attaching creditors, are all residents of the same State. The claim made by the assignee, as well as by the attaching creditors, is of Brooks' interest in the money in the hands of the garnishees. If the Miller heirs have an equitable right to more than one-half of the money now in the hands of the garnishees, it is not perceived why that question may not be determined by an adjustment of the partnership accounts of the original firm in the courts of that State.

"The rule here announced is not in conflict with Rhawn vs. Pearce, 110 111., 350. In that case the assignment was not voluntary but resulted by the laws of the State of Pennsylvania. A statutory assignment will not be enforced against attaching creditors of another State. May vs. First National Bank of Attleboro, supra."