Recognition of Foreign Judgments

Question 1

Judgments of the Courts of Sister American States

Answer 1

Full Faith & Credit Clause

Exceptions to Full Faith & Credit:

• Lack of jurisdiction
• Lack of finality
• Judgment was NOT on the merits

Question 2

Judgments of Foreign Countries

Answer 2

State Law Governs (ABSENT an applicable treaty)

Question 3

Family Law Judgments

Answer 3

Judgment of Divorce = One spouse was domiciled

Judgment for Alimony & Property Rights = PJ over spouse who’s rights being determined

Child Custody Decrees = Child’s home state

Divisible Divorce Doctrine = Recognize good parts & ignore the bad