Comments on: Full Faith and Credit for Judgments Recognizing Judgments? https://lettersblogatory.com/2023/09/26/full-faith-and-credit-for-judgments-recognizing-judgments/ The Blog of International Judicial Assistance Thu, 05 Oct 2023 00:13:48 +0000 hourly 1 https://wordpress.org/?v=6.9.4 By: Ted Folkman https://lettersblogatory.com/2023/09/26/full-faith-and-credit-for-judgments-recognizing-judgments/#comment-7362 Thu, 05 Oct 2023 00:13:48 +0000 https://lettersblogatory.com/?p=32159#comment-7362 In reply to Melissa Nutter.

How nice to hear from you, Melissa! I hope all is well. I’m going to make that my tagline: “the only attorney to finish tasks before a deadline.™”

]]> By: Melissa Nutter https://lettersblogatory.com/2023/09/26/full-faith-and-credit-for-judgments-recognizing-judgments/#comment-7353 Wed, 04 Oct 2023 16:25:01 +0000 https://lettersblogatory.com/?p=32159#comment-7353 I’m just saying hello and how I miss working with you, the only attorney to finish tasks before a deadline. Popping in and reading your blog gives me a satisfying sense of connection. I hope you and the family are doing well!

]]> By: Ted Folkman https://lettersblogatory.com/2023/09/26/full-faith-and-credit-for-judgments-recognizing-judgments/#comment-7324 Mon, 02 Oct 2023 14:59:51 +0000 https://lettersblogatory.com/?p=32159#comment-7324 In reply to Alejandro Manevich.

Alex, HMB is interesting! Am I right to think that in Canada the question is one of provincial rather than federal law? That’s interesting to me insofar as in the US, the question is made more pressing by the federal constitutional requirement of full faith and credit.

]]> By: Ted Folkman https://lettersblogatory.com/2023/09/26/full-faith-and-credit-for-judgments-recognizing-judgments/#comment-7294 Sat, 30 Sep 2023 17:34:46 +0000 https://lettersblogatory.com/?p=32159#comment-7294 In reply to Alejandro Manevich.

Thanks, Alex! I will check out that case.

]]> By: Alejandro Manevich https://lettersblogatory.com/2023/09/26/full-faith-and-credit-for-judgments-recognizing-judgments/#comment-7280 Fri, 29 Sep 2023 18:58:41 +0000 https://lettersblogatory.com/?p=32159#comment-7280 Ted, you may have missed the judgment from the Ontario Court of Appeal a year ago on this same question: H.M.B. Holdings Limited v. Antigua and Barbuda, 2022 ONCA 630. The court held, in brief, that such so-called “ricochet judgments” (I love this term—we need to popularize it outside Canada) could not be recognized at common law, relying on large part on the analysis of the Supreme Court of Canada in—wait for it—Chevron Corp. v. Yaiguaje, 2015 SCC 42. Lago Agrio is really the private international law gift that keeps on giving!

Alex

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