103 A.D.3d 1183
N.Y. App. Div.2013Background
- Plaintiff, a Delaware corporation with PA nexus, sues defendant, a New York corporation, over contracts for chondroitin sulfate in 2006 three shipments.
- In 2007, plaintiff filed in the Middle District of Pennsylvania; the federal court dismissed for lack of personal jurisdiction.
- Plaintiff then sued in Pennsylvania state court alleging the same breaches; contracts' General Terms and Conditions designated PA law and PA/PA federal disputes; defendant was served and defaulted.
- Plaintiff sought enforcement of the PA default judgment in a subsequent action and defendant moved to dismiss on lack of personal jurisdiction and statute of limitations grounds.
- Supreme Court denied the motion; the Full Faith and Credit Clause governs enforcement of sister-state judgments, focusing on whether the rendering court had jurisdiction; the federal order did not deprive PA court of jurisdiction; timeliness of remaining claims hinged on tolling by partial payments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the PA default judgment can be enforced despite purported lack of personal jurisdiction. | Plaintiff argues PA court had jurisdiction via contract terms. | Defendant contends PA court lacked personal jurisdiction over it. | Enforcement affirmed; PA court had jurisdiction for the default judgment. |
| Whether the remaining breach and account-stated claims are time-barred. | Four-year clocks may have been tolled by partial payments. | More than four years elapsed; time-barred absent tolling. | Triable issue on tolling; not conclusively time-barred. |
| Whether the federal dismissal order collaterally attacks or undermines the PA default judgment. | Dismissal could estop or toll collateral challenges in PA court. | Order cannot be used tocollateral attack the PA judgment. | No collateral attack; full faith and credit limits inquiry to jurisdiction of rendering court. |
Key Cases Cited
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (due process limits for personal jurisdiction requirements)
- International Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (minimum contacts for jurisdiction)
- Fiore v. Oakwood Plaza Shopping Ctr., 78 N.Y.2d 572 (N.Y. 1991) (full faith and credit scope and collateral considerations)
- Hopewell Estates, Inc. v. Kent, 646 A.2d 1192 (Pa. 1994) (collateral estoppel and waiver under PA law)
- Oldham v. McRoberts, 21 A.D.2d 231 (N.Y. 1965) (limits on collateral attack on judgments)