Conflicts of Law

Question 1

Full Faith and Credit Requirements

Answer 1

(i) proper jurisdiction in rendering court
(ii) judgment was on the merits
(iii) judgment was final

Question 2

defenses to FFC

Answer 2

(i) judgment was penal

ii) judgment is subject to equitable defense in rendering state (e.g., was obtained by extrinsic, not intrinsic, fraud

Question 3

recognition of foreign country judgments

Answer 3

discretionary. courts look to whether (i) foreign court had jurisdiction, (ii) fair procedures were used in adjudicating the case