Sentinel Acceptance, Ltd., L.P. v. Hodson Auto Sales & Leasing

Brief Fact Summary.

Plaintiff won arbitration against Defendants in California and filed a garnishment order in Missouri. Defendant filed a motion to quash the garnishment order on the basis of surprise.

Synopsis of Rule of Law.

Under Missouri precedent, state courts are obligated to give full faith and credit to a judgment of another state unless that judgment is void for lack of personal or subject matter jurisdiction, or is obtained by fraud.

Facts.

Sentinel Acceptance (Plaintiff) sued Hodson Auto Sales and Ms. Hodson (Defendants) in California. The Superior Court of the State of California entered a judgment awarding Plaintiff $16,052.11. Plaintiff then filed a garnishment order in Missouri to enforce the California Superior Court’s judgment. Defendant filed a motion to quash the garnishment order on the basis of a Missouri law which did not allow enforcement of surprise judgements, arguing that her husband ran the day-to-day of the business and she had no knowledge of the lawsuit in California.

Issue.

May a Missouri court quash a California judgment on the basis of surprise?

Held.

No, the foreign judgment cannot be quashed on the basis of surprise. Reversed.

Discussion.

The Court determined that the trial court erred in concluding that a foreign judgment could be quashed on the basis of surprise. Foreign judgments are subject to Missouri laws regarding the registration of judgments, but are not subject to Missouri laws regarding the judgment itself. Defendant did not properly argue before the Court that the judgment was void for lack of personal or subject matter jurisdiction or was obtained by fraud.