Fidelity National Financial v. Colin Friedman, 935 F.3d 696

Fidelity obtained a multimillion-dollar federal judgment in the Central District of California against the Friedmans and Meshkatais; the judgment became final in 2003.
Fidelity registered the California judgment in the District of Arizona under 28 U.S.C. § 1963, later attempted renewal, and the Arizona court held the renewal expired under Arizona’s five-year enforcement statute.
To circumvent the Arizona statute of limitations, Fidelity registered the California judgment in the Western District of Washington (creating a "Washington Judgment") and then registered that Washington Judgment back in Arizona (the "Second Arizona Judgment").
Defendants moved under Fed. R. Civ. P. 60(b) to vacate the Second Arizona Judgment, arguing (1) § 1963 does not permit successive registration and (2) the Washington court lacked personal jurisdiction, making the Washington Judgment void.
This Court in Fidelity I held successive registration was permissible under § 1963 and remanded; on remand the Arizona district court considered and held that registration requires personal jurisdiction in the registering district and vacated the Second Arizona Judgment.
On appeal from that Rule 60(b)(4) ruling, the Ninth Circuit reversed, holding § 1963 does not require personal jurisdiction in the registering district and that due process is not offended by registration of a pre-existing federal judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 28 U.S.C. § 1963 requires personal jurisdiction over the judgment debtor in the district of registration	Fidelity: § 1963 permits registration in “any other district” by filing a certified copy; no jurisdictional limit exists	Defendants: Registration creates a new judgment; thus the registering court must have personal jurisdiction or the new judgment is void	Held: § 1963 contains no personal-jurisdiction requirement; registration is a clerical/administrative act and may occur in districts lacking personal jurisdiction
Whether the Due Process Clause independently requires personal jurisdiction at registration because registration creates a “new” judgment	Fidelity: Due process protects against being sued in a distant forum; registration is not a new suit or obligation—due process was satisfied in the original adjudication	Defendants: Fidelity I treated a registration as creating a new judgment rendered by the registering court, so constitutional jurisdictional limits apply	Held: Due process does not impose a personal-jurisdiction requirement on mere registration of an existing federal judgment because registration does not involve maintaining a suit or requiring the debtor to defend anew; the original adjudication satisfied due process

Fidelity Nat’l Fin., Inc. v. Friedman, 803 F.3d 999 (9th Cir. 2015) (holding successive registration under § 1963 creates a registrable judgment)
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (personal-jurisdiction minimum-contacts analysis protects against burdens of distant litigation)
Kulko v. Superior Court, 436 U.S. 84 (U.S. 1978) (contacts test and fair play/substantial justice framework)
Int’l Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (foundational minimum-contacts standard for personal jurisdiction)
Shaffer v. Heitner, 433 U.S. 186 (U.S. 1977) (presence of property in a forum does not always confer jurisdiction)
In re Ctr. Wholesale, 759 F.2d 1440 (9th Cir. 1985) (judgment is void if the court that rendered it lacked jurisdiction)
Export Grp. v. Reef Indus., Inc., 54 F.3d 1466 (9th Cir. 1995) (de novo review of Rule 60(b)(4) challenges to judgment validity)
Air Transp. Ass’n of Am. v. Prof’l Air Traffic Controllers Org. (PATCO), 699 F.2d 539 (D.C. Cir. 1983) (registration is a rapid clerical procedure not requiring judicial intervention)
Stanford v. Utley, 341 F.2d 265 (8th Cir. 1965) (§ 1963 adopted to eliminate necessity and expense of a second lawsuit)