Foreign Judgments

In the United States, the recognition and enforcement of foreign-country judgments is generally governed by state law. Most states have adopted one of two Uniform Acts that provide for the recognition and enforcement of foreign money judgments subject to certain exceptions, including lack of jurisdiction, fraud, and public policy. There is also a federal statute, the SPEECH Act, that governs the recognition and enforcement of foreign defamation judgments. The United States has signed two judgments treaties, the 2005 Hague Convention on Choice of Court Agreements and the 2019 Hague Judgments Convention, but neither has yet been sent to the Senate for ratification.

A Primer on Foreign Judgments

By William S. Dodge and John F. Coyle

March 25, 2022 posted in: Foreign Judgments

[Updated August 22, 2025] In the United States, the recognition and enforcement of foreign-country judgments is generally governed by state law. Nevertheless, the law on foreign judgments is fairly uniform throughout the United States because most states have adopted one of two Uniform Acts. These Acts establish a presumption that final, conclusive, and enforceable foreign…

Recent Posts

Who Owns the Li Manuscripts?

By John F. Coyle

April 8, 2026 posted in: Foreign Judgments

Li Rui was born in China in 1917. He joined the Chinese Communist Party (CCP) in 1937 and became Chairman Mao’s personal secretary in 1958. After Li Rui publicly criticized Mao and the CCP in 1959, he was sent to jail and work camps for the next twenty years. In 1979, Li Rui was released…

Confusion in the Recognition of Foreign Country Judgments

By John F. Coyle

March 18, 2026 posted in: Foreign Judgments

There are at least three different legal regimes in the United States that govern the recognition of foreign judgments. While the distinctions between these regimes are clear to me—and, I suspect, to many readers of this blog—the same is not necessarily true for many judges and practicing attorneys. In this post, I first discuss a…

Chinese Judgments Go Global: Emerging Systemic Challenges and Confidence Deficit

By Wenliang Zhang and Meng Yu

January 29, 2026 posted in: Foreign Judgments

Over the past decade, many jurisdictions have witnessed a marked increase in cases involving the cross-border recognition and enforcement of judgments. This trend reflects the practical need to recover debts across borders and to prevent evasive debtors from hiding assets abroad. China is rapidly catching up with the international community in this domain, with a…

Uniform Foreign-Country Money Judgments Recognition Act (2005)

Uniform Foreign Money-Judgments Recognition Act (1962)

SPEECH Act, 28 U.S.C. §§ 4101-4105

Restatement (Fourth) of Foreign Relations Law §§ 481-490

Hague Convention on Choice of Court Agreements (2005)

Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (2019)

Ronald A. Brand, The Hague Judgments Convention in the United States: A “Game Changer” or A New Path to the Old Game?, 82 U. Pitt. L. Rev. 847 (2021) (SSRN)

William S. Dodge & Wenliang Zhang, Reciprocity in China-Us Judgments Recognition, 53 Vand. J. Transnat’l L. 1541 (2020) (SSRN)

Ronald A. Brand, The Continuing Evolution of U.S. Judgments Recognition Law, 55 Colum. J. Transnat’l L. 277 (2017) (SSRN)

John F. Coyle, The SPEECH Act and the Enforcement of Foreign Libel Judgments in the United States, 18 Y.B. Priv. Int’l L. 245 (2017) (SSRN)

Tanya J. Monestier, Whose Law of Personal Jurisdiction? The Choice of Law Problem in the Recognition of Foreign Judgments, 96 B.U. L. Rev. 1729 (2016) (BU)

Linda J. Silberman & Aaron D. Simowitz, Recognition and Enforcement of Foreign Judgments and Awards: What Hath Daimler Wrought?, 91 N.Y.U. L. Rev. 344 (2016) (SSRN)

Ronald A. Brand, Understanding Judgments Recognition, 40 N.C. J. Int’l L. & Com. Reg. 877 (2015) (SSRN)

John F. Coyle, Rethinking Judgments Reciprocity, 92 N.C. L. Rev. 1109 (2014) (SSRN)

Wiliam S. Dodge, Breaking the Public Law Taboo, 43 Harv. Int’l L.J. 161 (2002) (SSRN)

Linda J. Silberman & Andreas F. Lowenfeld, A Different Challenge for the ALI: Herein of Foreign Country Judgments, an International Treaty, and an American Statute, 75 Ind. L.J. 635 (2000) (Indiana)