https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/ The Blog of International Judicial Assistance Mon, 01 Sep 2025 21:24:04 +0000 hourly 1 https://wordpress.org/?v=6.9.4 https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-42169 Mon, 01 Sep 2025 21:24:04 +0000 http://lettersblogatory.com/?p=869#comment-42169 […] against granting a 1782 application in a foreign defamation case, especially in light of the SPEECH Act, the federal statute barring recognition of foreign defamation judgments when the foreign law does […]

]]> https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-24174 Fri, 13 Dec 2024 20:24:06 +0000 http://lettersblogatory.com/?p=869#comment-24174 […] HT to Antonin I. Pribetic for his post on the case of the day, Sanchez v. Lord (Mo. Ct. App. 2011), the first case of the day applying the SPEECH Act. Our previous coverage of the Act, which provides a rule of non-recognition for foreign defamation judgments that do not comply with U.S. constitutional law, is here. […]

]]> https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-22873 Mon, 25 Nov 2024 14:19:04 +0000 http://lettersblogatory.com/?p=869#comment-22873 […] federal appellate decision to focus on the SPEECH Act in a major way. Readers may want to refer to overview post of the Act. In short, the Act creates a rule against recognition of foreign defamation judgments if […]

]]> https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-8840 Sun, 10 Dec 2023 23:59:09 +0000 http://lettersblogatory.com/?p=869#comment-8840 […] Act. Here is another question I’ve never seen addressed in practice. A federal statute, the SPEECH Act, forbids US courts from recognizing foreign defamation judgments when their defamation law is […]

]]> https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-126 Thu, 19 Apr 2012 10:03:47 +0000 http://lettersblogatory.com/?p=869#comment-126 […] if he prevails, will be unenforceable in the United States. Presumably this is on account of the SPEECH Act. I would go further and say that if the case were litigated in the United States in the first […]

]]> https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-125 Mon, 12 Mar 2012 10:01:12 +0000 http://lettersblogatory.com/?p=869#comment-125 […] be looking for ways to argue that the public policy embodied in the SPEECH Act (which we discussed in April 2011) provides a discretionary basis for denying judicial assistance. The Act bars recognition of […]

]]> https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-124 Thu, 05 Jan 2012 19:05:20 +0000 http://lettersblogatory.com/?p=869#comment-124 […] before the Ecuadoran parliament on the recognition and enforcement of foreign judgments. I’ve written before about the SPEECH Act, the new US statute that forbids recognition and enforcement of foreign […]

]]> https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-123 Fri, 15 Jul 2011 11:10:22 +0000 http://lettersblogatory.com/?p=869#comment-123 […] an earlier post, we reviewed the main provisions of the Act, notably the provision allowing U.S. residents and […]

]]> https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-122 Fri, 24 Jun 2011 11:05:32 +0000 http://lettersblogatory.com/?p=869#comment-122 […] posts continue to attract significant attention long after they are published. These include the post on the SPEECH Act and recognition of foreign defamation judgments; the post on the Australian […]

]]> https://lettersblogatory.com/2011/04/07/recognition-of-foreign-judgments-in-defamation-cases-the-speech-act/#comment-121 Thu, 21 Apr 2011 12:36:21 +0000 http://lettersblogatory.com/?p=869#comment-121 […] HT to Antonin I. Pribetic for his post on the case of the day, Sanchez v. Lord (Mo. Ct. App. 2011), the first case of the day applying the SPEECH Act. Our previous coverage of the Act, which provides a rule of non-recognition for foreign defamation judgments that do not comply with U.S. constitutional law, is here. […]

]]>