In 1895, the Supreme Court decided Hilton v Guyot, the foundational case on foreign judgments law. The underlying lawsuit was straightforward. Two American entrepreneurs were sued in Paris by their French business associates in connection with a commercial dispute that occurred in France. When the plaintiffs prevailed, they brought their French money judgment to US court, hoping to reach the defendants’ US-based assets. With these features as backdrop – a straightforward lawsuit abroad, leading to a foreign money judgment, in a country with which US courts traditionally interacted – the Supreme Court formulated a liberal rule on foreign judgments. A foreign money judgment against a US citizen is presumptively binding if the rendering court had jurisdiction, the proceeding followed a ‘civilized jurisprudence’, and the judgment’s country of origin reciprocally gave effect to US judgments. … (more)
[Yanbai Andrea Wang, Transnational Litigation Blog, 18 June 2026]
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