Case of the Day: Resorts World at Sentosa v. Chan

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.

About Ted Folkman

Ted Folkman is a shareholder with Murphy & King, a Boston law firm, where he has a complex business litigation practice. Folkman also serves as an arbitrator and is a member of the Commercial and Consumer Panels of the American Arbitration Association. He is the author of International Judicial Assistance (MCLE 2d ed. 2016), a nuts-and-bolts guide to international judicial assistance issues, and of the chapter on service of process in the ABA's treatise on International Aspects of US Litigation (J. Berger, ed. 2017), and he is the publisher of Letters Blogatory, the Web's first blog devoted to international judicial assistance, which the ABA recognized as one of the best 100 legal blogs in 2012 and 2014 - 2016.

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