Fidelity National Financial v. Colin Friedman, 803 F.3d 999

Fidelity obtained a multimillion-dollar fraud judgment in the Central District of California in 2002; final May 15, 2003, with defendants owing over $10 million including interest.
Fidelity registered the California judgment in the District of Arizona in 2002 under 28 U.S.C. § 1963; the Arizona registration expired in 2007 under state statute.
Efforts to renew or re-register the Arizona judgment were rejected by the district court.
In 2011 Fidelity registered the California judgment in the Western District of Washington, and Fidelity then registered the Washington judgment in the District of Arizona.
Defendants moved under Rule 60(b)(4) to vacate the second registration as void; the district court vacated the second registration, ruling only an original judgment may be registered under § 1963.
The Ninth Circuit held that a registered judgment itself may be registered; § 1963 provides that a registered judgment has the same effect as a district-court judgment and may be enforced accordingly.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May a registered judgment be registered again under § 1963?	Fidelity argues § 1963 permits registration of a registered judgment.	Friedman argues only original judgments may be registered.	Yes; a registered judgment may be registered.
Whether a registered judgment qualifies as a ‘judgment in an action for the recovery of money or property’ for § 1963.	Fidelity contends the registered judgment is within § 1963’s scope.	Friedman contends it is not an original judgment.	It qualifies as a judgment for § 1963 purposes.
Effect of registering a registered judgment on the statute of limitations concerns.	Fidelity asserts routine enforcement, regardless of prior expirations.	Friedman argues potential title to new limitations issues are controlled by the original jurisdictions.	The statute of limitations concerns are governed by the registering state's law; registration semantics control.

Hilao v. Estate of Marcos, 536 F.3d 980 (9th Cir. 2008) (registering state limitations apply to registered judgments)
Del Prado v. B.N. Development Co., 602 F.3d 660 (5th Cir. 2010) (registered judgment may be registered and enforced in another court)
De Leon v. Marcos, 742 F. Supp. 2d 1168 (D. Colo. 2010) (district court rejected reasoning that only original judgments may be registered)
Amalgamated Transit Union Local 1309 v. Laidlaw Transit Servs., Inc., 448 F.3d 1092 (9th Cir. 2006) (absurdity canon does not override statutory text)
SEC v. McCarthy, 322 F.3d 650 (9th Cir. 2003) (definition of an action includes civil judicial proceedings)