In Monday’s post I mentioned John Coyle’s new paper, Rethinking Judgments Reciprocity, which is forthcoming in the North Carolina Law Review, but it’s worth its own post. The main point of the paper is to provide a model for thinking about whether to include a reciprocity requirement in judgment recognition statutes. But what really stands out in the paper, in my view at least, is John’s efforts at taking an empirical look at actions for judgment recognition. How many of them are there, from what countries do the judgments come, and how much money is at stake? The table summarizing his findings is worth the price of admission (which is zero, since the paper is available on SSRN.
The case of the day is Mont Blanc Trading Ltd. v. Khan (S.D.N.Y. 2014). Mont Blanc, which had won an arbitral award at the LCIA and then won confirmation at the English High Court, came to the US seeking recognition and enforcement. But a simple error will send Mont Blanc back to the drawing board.
The case of the day is Panchenkova v. Chigirinsky (Conn. Super. Ct. 2013), is an action for recognition and enforcement of a Russian divorce judgment.