Enforcing Foreign Judgments in Non-Uniform Act States
The recognition and enforcement of foreign judgments in the United States are generally governed by state law. Most states have adopted one of two uniform acts to address this. Twenty-nine states and the District of Columbia have adopted the 2005 Uniform Foreign-Country Money Judgments Recognition Act. Nine additional states still rely on its predecessor, the…
Continue ReadingHow (Not) to Decide Whether a Foreign Judgment Is Preclusive
Foreign judgments are generally entitled to recognition in the United States. Beneath that simple statement, however, lie many complexities. When lawyers and judges do not understand those complexities, they are likely to go astray. That seems to be what happened in Wash v. Finch, a recent federal decision in the District of New Jersey. This…
Continue ReadingForeign-Country Judgments and Full Faith and Credit
Article IV, section 1 of the U.S. Constitution begins by stating: “Full Faith and Credit shall be given in each State to the public Acts, Records, and judicial Proceedings of every other State.” Congress has extended this principle to judgments from U.S. territories and possessions too, providing in the Full Faith and Credit Act that…
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