Following federal case law interpreting two statutes on the enforcement of foreign and out-of-state judgments, the state Superior Court has ruled that a foreign judgment cannot be valid without first being recognized by state courts.
On July 29, a three-judge panel of the court held that the trial court in Louis Dreyfus Commodities Suissa Sa v. Financial Software Systems correctly declined to enforce a judgment that Louis Dreyfus Commodities obtained in the English court system. The company had sought to enforce the judgment by invoking the Uniform Enforcement of Foreign Judgments Act; however, Judge James J. Fitzgerald III said the company needed to first ensure that the judgment was valid in Pennsylvania courts under the Uniform Foreign Money Judgment Recognition Act.
