Jonas v. Jonas, 2012 MT 109N

This Montana Supreme Court case involves Edwin Jonas and Linda Jonas in a long-running interstate divorce dispute beginning with Linda's 1988 New Jersey divorce filing.
A 2006 New Jersey judgment awarded Edwin substantial arrears, alimony, and fees, and included measures to secure payment; Edwin defaulted and did not appeal to the New Jersey Supreme Court.
Linda domesticated the New Jersey judgment in Montana in December 2009 under the Uniform Enforcement of Foreign Judgments Act.
Edwin moved to stay/vacate the Montana-registered judgment; the Montana district court denied, and Edwin’s related motions were subsequently denied for failure to file a supporting brief.
Edwin challenged the Montana decision via M.R. Civ. P. 60 relief; the district court found no merit, citing full faith and credit and res judicata; Linda sought costs and fees under § 37-61-421, MCA, which the court denied.
The Montana Supreme Court affirmed, concluding no abuse of discretion on Rule 60 relief or on costs/fees, and noting the cautionary stance toward continued protracted litigation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion denying Rule 60 relief	Edwin argues New Jersey judgment not entitled to full faith and credit due to default	Jonas asserts full faith and credit applies; relitigation barred by res judicata	No abuse; full faith and credit applies; res judicata bars relitigation
Whether the district court abused its discretion denying costs under § 37-61-421	Linda sought costs and fees for this round of litigation	Edwin's conduct prolonged proceedings; no award warranted	No abuse; court’s cautionary stance appropriate; no costs awarded to Linda

Carr v. Bett, 291 Mont. 326 (Mont. 1998) (default judgments from sister states entitled to full faith and credit unless invalid or unenforceable)
Matsumoto v. Matsumoto, 792 A.2d 1222 (N.J. 2002) (fugitive disentitlement doctrine invoked; prohibits relief when fugitive evades process)