Standard Chartered Bank v. Ahmad Hamad Al Gosaibi & Bros.
99 A.3d 936
| Pa. Super. Ct. | 2014Background
- AHAB appeals a Philadelphia court’s denial of its motion to vacate a New York judgment enforcing a Bahraini money judgment in favor of Standard Chartered.
- Standard Chartered obtained a Bahraini judgment in 2010 for $27,207,400 plus interest and costs after AHAB failed to transfer dollars in a 2009 currency exchange.
- New York recognized the Bahraini judgment in 2012 under its Recognition Act, and judgment was entered in New York in 2013.
- AHAB sought to vacate the New York recognition, and then challenged Pennsylvania’s enforcement of the New York judgment under 42 Pa.C.S. § 4306 and related theories.
- The Pennsylvania trial court held the New York judgment entitled to full faith and credit and denied vacatur, invoking the U.S. Constitution, the Full Faith and Credit Act, and Pennsylvania’s Enforcement Act.
- The Superior Court affirmed, holding that full faith and credit applies to a valid New York judgment recognizing a foreign judgment, and that Pennsylvania cannot, on public policy grounds, undermine this result.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether full faith and credit required vacating the New York judgment. | AHAB argues New York recognition should not be given full faith and credit. | Standard Chartered contends the NY judgment is valid and entitled to full faith and credit in PA. | No abuse; full faith and credit accorded; denial affirmed. |
| Whether Pennsylvania may apply public policy to override recognition of a valid sister-state judgment. | AHAB claims PA policy may bar enforcement despite recognition in NY. | Standard Chartered asserts no public policy exception overrides recognition. | Public policy ground rejected; recognition upheld. |
| Whether the Enforcement Act governs recognition of a foreign nation judgment versus the Recognition Act. | AHAB contends Pennsylvania may scrutinize under PA’s Recognition Act rather than automatic enforcement via Enforcement Act. | PA law treats foreign nation judgments recognized in NY as enforceable under Enforcement Act without extra scrutiny. | Enforcement Act controls and recognizes NY-acknowledged foreign judgments; affirmed. |
Key Cases Cited
- Baker ex rel. Thomas v. Gen. Motors Corp., 522 U.S. 222 (1998) (full faith and credit for money judgments nationwide)
- Greate Bay Hotel & Casino, Inc. v. Saltzman, 415 Pa. Super. 408 (1992) (enforcement of foreign judgments; public policy constraints limited)
- Noetzel v. Glasgow, Inc., 487 A.2d 1372 (Pa. Super. 1985) (full faith and credit for foreign judgments; due process considerations)
- Wilkes ex rel. Mason v. Phoenix Home Life Mut. Ins. Co., 902 A.2d 366 (Pa. 2006) (public policy limits on recognition; res judicata effect of foreign judgments)
- Olympus Corp. v. Canady, 962 A.2d 671 (Pa. Super. 2008) (abuse of discretion standard; interpretation of statutes)