Under Washington’s enactment of the Uniform Foreign-Country Money Judgment Recognition Act, the district court properly enforced a judgment rendered in Holland. The Act allows a domestic court, in its discretion, to deny enforcement of a foreign judgment if the foreign process generally or in the particular case did not afford the judgment debtor due process. The Act does not define what standard is used to decide whether due process was afforded. This decision holds that the proper standard is “procedures compatible with the requirements of fundamental fairness” rather than the specific constitutional due process guarantees afforded litigants in U.S. courts. Here, the Dutch courts afforded defendant a procedure consistent with fundamental fairness even though they limited defendant’s discovery and an appellate court reversed one of the trial court’s key findings.
Ninth Circuit Court of Appeals (Bea, J.); October 25, 2017); 2017 WL 4799263.