Tropic Leisure Corp. v. HaileyÂ, 249 N.C. App. 198

Plaintiffs (Tropic Leisure Corp. and Magens Point, Inc.), Virgin Islands corporations, obtained a default small-claims judgment in the Virgin Islands Superior Court against Hailey for $5,764 plus interest and costs.
Plaintiffs domesticated the foreign judgment in Wake County, North Carolina, under North Carolina’s Uniform Enforcement of Foreign Judgments Act (UEFJA).
Hailey moved for relief from the foreign judgment in North Carolina, arguing the Virgin Islands small-claims procedures violated his due process rights because they bar counsel and jury trials.
The North Carolina trial court denied Hailey’s motion and ordered enforcement of the judgment under the Full Faith and Credit Clause and the UEFJA.
Hailey appealed; he had not appeared or appealed in the Virgin Islands proceedings and did not raise the due process objections there.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Virgin Islands small-claims judgment is entitled to full faith and credit and enforceable in NC under the UEFJA	The judgment is presumptively entitled to full faith and credit because it was properly authenticated and filed under the UEFJA	The judgment should not be enforced because the Virgin Islands small-claims rules (no counsel; no jury) deprived Hailey of due process	Court affirmed: properly filed foreign judgment creates a presumption of enforceability; Full Faith and Credit applies and UEFJA governs enforcement
Whether a defendant may collaterally attack a foreign judgment in NC on due process grounds not raised in the rendering court	Enforcement is proper; defenses must be directed to validity/enforcement and cannot be a collateral attack on issues the defendant could have litigated in the rendering forum	Hailey may challenge enforcement in NC based on deprivation of due process arising from the rendering court’s procedures	Court held defendant cannot mount a collateral attack in NC on issues he could have and did not raise in the rendering jurisdiction; such defenses are barred under Full Faith and Credit/UEFJA

DOCRX, Inc. v. EMI Servs. of N.C., LLC, 367 N.C. 371 (N.C. 2014) (Full Faith and Credit/UEFJA principles and list of defenses to foreign judgments)
State of New York v. Paugh, 135 N.C. App. 434 (N.C. Ct. App. 1999) (foreign judgment given same effect in sister state as in rendering state)
Bell Atl. Tricon Leasing Corp. v. Johnnie’s Garbage Serv., Inc., 113 N.C. App. 476 (N.C. Ct. App. 1994) (foreign judgment must satisfy rendering state’s requisites to receive full faith and credit)
Meyer v. Race City Classics, LLC, 235 N.C. App. 111 (N.C. Ct. App. 2014) (properly filed materials create presumption that foreign judgment is entitled to full faith and credit)
Bergen v. Bergen, 439 F.2d 1008 (3d Cir. 1971) (Full Faith and Credit Clause applies to judgments from the Virgin Islands)