Nader v. SERODY, 43 A.3d 327

Nader challenged a Pennsylvania cost judgment obtained against him in the Pennsylvania courts for nominating-paper challenges; voters sought to enforce this judgment in DC.
The Pennsylvania courts concluded the nominating papers lacked the required valid signatures; the Pennsylvania Supreme Court denied certiorari, and costs were assessed against Nader and his campaign.
The Pennsylvania judgment was filed in DC Superior Court under the Uniform Enforcement of Foreign Judgments Act (UEFJA), §15-352, making it enforceable as a DC judgment.
Nader moved in DC Superior Court under Rule 60(b) and Rule 41(b) to set aside or dismiss, arguing newly discovered evidence and other defects; the court denied both motions.
DC Superior Court deferred to the Pennsylvania judgment’s merits under res judicata/Full Faith and Credit principles, keeping the enforcement intact.
On appeal, the DC Court of Appeals addressed enforcement scope under the Full Faith and Credit Clause and constrained potential defenses to those allowed by the UEFJA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 60(b) relief was properly denied	Nader contends newly discovered evidence warrants relief.	Voters argue res judicata and finality foreclose 60(b) relief in DC.	Yes; 60(b) relief properly denied (preclusion and finality favored).
Whether 41(b) relief/dismissal was proper for enforcement	Nader claims stay and restitution issues render enforcement premature.	Enforcement under 15-352 is limited; issues should have been raised in PA.	Yes; 41(b) relief denied; enforcement confirmed.
Whether the DC court could enforce a foreign judgment despite potential due process or fraud concerns	Claims of fraud or due process defects in PA proceedings could defeat enforcement.	Defenses under UEFJA are narrow and do not relitigate merits; Full Faith and Credit controls.	Held that defenses are limited; generally uphold enforcement unless substantial due-process or fraud concerns arise under UEFJA principles.
Whether the automatic ten-day Rule 62(a) period for executions was violated	Garnishee bank executions occurred within improper time after stays.	Any delay issue is moot because Rule 60(b) relief was denied and finality was preserved.	Moot; no error; enforcement upheld.

Underwriters Nat'l Assurance Co. v. North Carolina Life & Accident and Health Ins. Guaranty Ass'n, 455 U.S. 691 (1982) (Full Faith and Credit dictates equal recognition of foreign judgments)
Durfee v. Duke, 375 U.S. 106 (1963) (finality and res judicata principles across states)
Data Mgmt. Sys., Inc. v. EDP Corp., 709 P.2d 377 (Utah 1985) (UEFJA limitations must not defeat Full Faith and Credit)
Carr v. Rose, 701 A.2d 1065 (D.C.1997) (collateral attack limits on foreign judgments in DC)
Jones v. Roach, 575 P.2d 345 (Ariz. App. 1977) (fraud or lack of jurisdiction can bar enforcement of foreign judgments)
In re Delaney, 819 A.2d 968 (D.C.2003) (extrinsic vs intrinsic fraud in judgments)
Angel v. Bullington, 330 U.S. 183 (1947) (fraud on the court as a basis to bar enforcement)
McKnett v. St. Louis & S.F. Ry. Co., 292 U.S. 230 (1934) (statutory limits on jurisdiction and enforcing judgments)