The case of the day is Resorts World at Sentosa v. Chan (D. Hawai’i 2016). Michelle Mai Chan incurred a gambling debt at Resorts World Sentosa, a Singapore resort and casino. Resorts World sued her in the Singapore High Court and obtained a default judgment in the principal amount of S$1.16 million. Resorts World then sought recognition and enforcement in Hawai’i, and it moved for summary judgment.

Chan argued that the judgment was not final and enforceable in Singapore because it was not a judgment on the merits but rather a default judgment (UFCMJRA § 3 requires that a judgment be “final, conclusive, and enforceable” under the foreign law). Singapore law provides that a default judgment can be set aside “on such terms as [the court] thinks just,” but the judgment is final and conclusive unless and until set aside, and in any case Chan had not sought to set aside the judgment in Singapore. Therefore, the court correctly granted the motion for summary judgment.