Brief Fact Summary.
Sentinel Acceptance Ltd. (Sentinel) sought to register a California arbitration award against HodsoninAuto Sales & Leasing, Inc. (Hodson) inMissuori seeking to garnish Hodson’s assets to satisfy the arbitration proceedings.
Synopsis of Rule of Law.
The full faith and credit clause only permits a court to quash a foreign state’s judgment the court lacked personal or subject matter jurisdiction, and the judgment was fraudulently secured.
A judgment is entitled to full faith and credit -- even as to questions of jurisdiction -- when the second court's inquiry discloses that those questions have been fully and fairly litigated and finally decided in the court which rendered the original judgment.View Full Point of Law
Hodson, a Missouri resident, was the president of HodsonAutosales& Leasing, Inc. (Hodson Auto), and her husband managed the company’s day-to-day affairs. Sentinel Acceptance Ltd. instituted arbitration against Hodson and Hodson auto in California and received an arbitration award. California Superior Court confirmed the arbitration award and Sentinel registered the arbitration award in Missouri to garnish Hodson and Hodson Auto’s assets to satisfy the arbitration proceedings. Hodson claimed that she was not personally served with information regarding the arbitration, whereas her husband retained California counsel for her who responded to Sentinel’s arbitration proceeding on her behalf. Hodson’s California counsel admitted that he only had contact with Hodson’s husband. Hodson sought to quash the California judgment on the basis of surprise because she had no knowledge of the arbitration proceedings. The trial judge quashed the registration and Sentinel appealed.
Whether surprise constitutes sufficient grounds to quash a foreign state’s judgment?
No. The judgment of the trial court is reversed. Surprise is not proper grounds to deny the full faith and credit of another state’s judgment. Hodson cannot make claims of personal jurisdiction because she failed to raise this claim at trial.
The full faith and credit clause upholds the judicial proceedings of a state in any other state. The full faith and credit clause only permits a court to quash a foreign state’s judgment the court lacked personal or subject matter jurisdiction, and the judgment was fraudulently secured.