Vaughan v. Graves, 291 P.3d 623

Bank sued relatives and a family trust in Oklahoma County under the Uniform Fraudulent Transfers Act (UFTA) while debtors' bankruptcy stay was in effect.
Bank had obtained bankruptcy judgments against Debtors in 2002 for roughly $364,024.75 plus costs and $393,472.66 in attorney fees; judgments totaled over $800,000 when combined with other proceedings.
Bank registered the bankruptcy judgments in Payne County (home of Debtors' homestead) in July 2002, domestication已完成 in Oklahoma.
Contempt and enforcement proceedings ensued (2007 order, 2010 order) to impose a charging order diverting 25% of Debtors’ income to satisfy the bankruptcy judgments.
In 2011, one judgment was filed in Oklahoma County; the trial court later attempted to enforce the 2010 order, but the court held registration in Oklahoma County was a prerequisite to enforcement; ultimately the court concluded belated registration could not validate void enforcement orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether registration of a foreign judgment is required before execution or judgment collection in a UFTA action	Bank argued UFTA procedures obviate separate registration	Court held registration is jurisdictional prerequisite	Registration required prior to enforcement actions under UFTA
Whether domestication of a foreign judgment via filing in Oklahoma allows execution/collection without preexisting registration	Bank argued filing suffices for enforcement within state	Domestic filing transfers but does not bypass registration requirement	Execution requires registration in the county from which it will issue
Whether belated registration (2011) retroactively authorizes enforcement of void orders	Registration after-the-fact should validate prior enforcement	Retroactivity not allowed; jurisdiction lacking at time of orders	Belated registration does not retroactively authorize enforcement of void orders
Whether the 2010 contempt order could be enforced before registration	Contempt should be enforceable under UFTA framework	No enforcement without proper registration	Orders void for lack of timely registration; cannot be enforced
Whether the filing of judgments in 2011 cured prior lack of jurisdiction	Filing cured jurisdiction	Cure does not retroactively validate void actions	2011 filing did not cure lack of jurisdiction for prior enforcement actions

Glass Law Firm P.C. v. Cornejo, 259 P.3d 883 (Okla. Civ. App. 2011) (questions of law reviewed de novo)
Kluver v. Weatherford Hosp. Auth., 859 P.2d 1084 (Okla. 1998) (questions of law reviewed de novo)
Heiman v. Atlantic Richfield Co., 807 P.2d 257 (Okla. 1991) (elements of jurisdiction described)
Producers Grain Corp. v. Carroll, 546 P.2d 285 (Okla. Civ. App. 1976) (domestication and enforcement of foreign judgments)
Valley Vista Dev. Corp., Inc. v. City of Broken Arrow, 766 P.2d 344 (Okla. 1988) (court may not rely on void findings; need new findings)