Hilton v. Guyot

Brief Fact Summary

Hilton (Plaintiff) and Libbey (Plaintiff) appealed from a federal district court holding that a French court judgment against them for amounts allegedly owed to a French firm was enforceable without retrial on the merits.

Synopsis of Rule of Law

No law has any effect, of its own force, beyond the limits of the sovereignty from which its authority is derived.

Facts

Hilton (Plaintiff) and Libbey (Plaintiff), New York citizens trading in Paris, were sued in France by Guyot (Defendant), the administrator of a French firm, for sums allegedly owed to that firm.  The Plaintiffs appeared and litigated the merits in the French proceeding.  The French court rendered a judgment against them that was affirmed by a higher court and became final.  Defendant then sought to enforce that judgment in federal district court in New York.  That court held the judgment enforceable without retrial on the merits.  The Plaintiffs then appealed to the U.S. Supreme Court.

Issue

Do laws have any effect, of their own force, beyond the limits of the sovereignty from which its authority is derived?

Held

(Gray, J.)  No.  No law has any effect, of its own force, beyond the limits of the sovereignty from which its authority is derived.  No sovereign is bound, unless by special compact, to execute within his dominions a judgment rendered by the tribunals of another state, and if execution be sought by suit upon the judgment or otherwise, the tribunal in which the suit is brought, or from which execution is sought, is, on principle, at liberty to examine into the merits of such judgment, and to give effect to it or not, as may be found just and equitable.  However, the general comity, utility and convenience of nations have established a usage among most civilized states, by which the final judgments of foreign courts of competent jurisdiction are reciprocally carried into execution, under certain regulations and restrictions, which differ in different countries.  Additionally, judgments rendered in France, or in any foreign country, by the laws of which our own judgments are reviewable upon the merits, are not entitled to full credit and conclusive effect when sued upon in this country, but are prima facie evidence only of the justice of the plaintiffs’ claim.  Reversed.

Dissent

(Fuller, C.J.)  The doctrine of res judicata should be applicable to domestic judgments as well as to foreign judgments, and rests on the same general ground of public policy that there should be an end of litigation.

Discussion

The Court’s decision in Hilton v. Guyot reflects the traditional rule of reciprocity.  According to this concept, foreign nation judgments were granted the same or comparable treatment as American judgments were given by the judgment nation.  Since the Court in Hilton found that French courts would not have enforced or executed a judgment rendered in this country, it therefore held that the French judgment at issue should be nonconclusive here.