Foreign Matters: How to obtain recognition of foreign-court judgments


In some cases, obtaining a judgment signals the end of litigation. In others, it may be just the beginning, particularly if the judgment comes from a foreign country. Turning a foreign judgment into actual relief requires two steps: recognition and enforcement. This article focuses on recognition.

Recognition in California is governed by the Uniform Foreign Money-Judgments Recognition Act for actions filed before Jan. 1, 2008, and the Uniform Foreign-Country Money-Judgments Recognition Act for actions filed on or after that date. The road to recognition can be tricky, but two recent developments — adoption of the revised Act and the California Supreme Court’s recent decision in Manco Contracting Co. v. Bezdikian, 45 Cal.4th 192 (2008) — have helped to clarify the standards and the process.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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