Background

• Guseinov obtained a California arbitration award and California judgment against Synergy Ventures and Burns for $5,223,980.09, with post-judgment interest accruing at 10% per year.
• Burns allegedly over-satisfied the judgment by transferring 2,975,579 shares of Synergy Ventures stock to Guseinov, valued at about $5.95 million, creating a dispute over satisfaction.
• Guseinov sought to enroll the California judgment in Tennessee under the Uniform Foreign Judgments Enforcement Act (UEFJA) and Full Faith and Credit Clause.
• Burns answered with counterclaims asserting satisfaction and asserting related defenses; he sought an evidentiary hearing on satisfaction.
• The trial court granted summary judgment enrolling the California judgment, denying Burns’s argument that post-judgment satisfaction defeats enrollment and refusing to hear a separate satisfaction defense.
• On appeal, the Tennessee Court of Appeals affirmed, holding satisfaction is not a defense to enrollment and due process was not violated by not holding an evidentiary hearing.

Issues

Key Cases Cited

• Four Seasons Gardening & Landscaping, Inc. v. Crouch, 688 S.W.2d 439 (Tenn. Ct. App. 1984) (recognizing exceptions to full faith and credit such as personal jurisdiction and public policy)
• Trustmark Nat’l Bank v. Miller, 209 S.W.3d 54 (Tenn. Ct. App. 2006) (fraud exception to enrollment)
• First State Bank of Holly Springs, Miss. v. Wyssbrod, 124 S.W.3d 566 (Tenn. Ct. App. 2003) (enrollment remains subject to defenses after registration)
• Coastcom, Inc. v. Cruzan, 981 S.W.2d 179 (Tenn. Ct. App. 1998) (three recognized exceptions to enrollment; separation of enrollment and enforcement)