Recognition

Question 1

Foreign Country

Answer 1

Comity?

-fair procedures
-jurisdiction
-final judgment on the merits

Y > recognize

Question 2

Sister State

Answer 2

Full faith and credit?
|
Y > Defenses?
|
N > Recognize

Question 3

Full Faith and Credit

Answer 3

Requires:
-court had personal and subject matter jurisdiction, unless those issues were fully litigated
-final judgment on the merits

*default judgment is merits; dismissal generally not

Question 4

FFC Defenses

Answer 4

Penal judgments or extrinsic fraud

*policy and misapplication of law are not