Defendant executed a promissory note in Michigan which contained a warrant of attorney authorizing the confessing of judgment by an attorney of any court of record. By statute in Michigan, such a power must be in a separate instrument before a pro confesso judgment can be entered. Plaintiff, an indorsee of the note, got a judgment rendered on the note in Illinois by virtue of such authorization. He then brought suit in Michigan upon this Illinois judgment. Held, the validity of the power is governed by the law of the place of contracting and so a judgment rendered under it will not be recognized in Michigan. Jones v. Turner (Mich. 1930) 228 N.W. 796.