Q&As

Is possible to enforce an English judgment in the US?

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Published on LexisPSL on 05/09/2014

The following Dispute Resolution Q&A provides comprehensive and up to date legal information covering:

  • Is possible to enforce an English judgment in the US?

Is possible to enforce an English judgment in the US?

The first point to note is that the US is not a signatory to any convention or treaty in relation to the enforcement of foreign judgments. The recognition and enforcement of an English judgment in the US will depend on the state in which that recognition and enforcement is sought. It should be noted that there are some considerable differences between the states.

There are many issues to consider in relation to enforcement of foreign judgments in the US and much will depend on the relevant state. A good starting point is Practice Note: Enforcement of foreign judgments—United Kingdom—Q&A guide as it provides information on the following issues in the form of questions and answers:

  1. treaties—is your country party to any bilateral or multilateral treaties for the reciprocal recognition and enforcement of foreign judgments? What is the country’s approach to entering into these treaties and what, if any, amendments or reservations has your country made to such treaties?

  2. intra-state variations—is there uniformity in the law on the enforcement of foreign judgments among different jurisdictions within the country?

  3. sources of law—what are the sources of law regarding the enforcement of foreign judgments?

  4. Hague Convention requirements—to the extent the enforcing country is a signatory of the Hague Convention on Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters,

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