Woo v. Spackman, 988 F.3d 47

Background

Woo, a former shareholder in a Korean public company, alleged Spackman (the company CEO) engineered a self‑dealing merger that violated Korean securities law and caused investor losses.
The Supreme Court of Korea affirmed a judgment for Woo (≈ $4.5M) in 2013; after unsuccessful attempts to relitigate, the Korean judgment became final.
A New York court recognized the Korean judgment under New York's recognition statute in Sept. 2018, entering a judgment for > $13M (principal plus accrued interest).
Woo filed the New York judgment in the U.S. District Court for the District of Massachusetts on Dec. 21, 2018, labeled as a "Registration of State Court Judgment," then served subpoenas on Spackman’s wife (Kim) in Massachusetts.
Kim moved to quash, arguing the district court lacked subject‑matter jurisdiction because 28 U.S.C. § 1963 authorizes registration only of certain federal judgments; the district court dismissed for lack of jurisdiction and later denied Woo’s motion for reconsideration (Woo first asserted diversity jurisdiction in that motion).
Woo appealed; the First Circuit reviewed whether § 1963 permits registration of state judgments and whether any alternate federal jurisdictional basis existed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 28 U.S.C. § 1963 authorizes registration of state‑court judgments in federal district court	§1963 allows registration of the New York (state) judgment in federal court	§1963 by its text applies only to judgments from listed federal courts, not state courts	§1963 does not authorize registration of state‑court judgments; it applies to judgments of specified federal courts only
Whether GE Betz supports federal registration of state judgments under §1963	GE Betz interprets §1963 to permit federal courts to register state judgments	GE Betz held only that §1963 does not bar federal jurisdiction when an independent basis exists; it did not hold §1963 authorizes registration	GE Betz is not authority for allowing §1963 to reach state judgments; it is limited to saying §1963 does not foreclose other jurisdictional bases
Whether the district court had diversity jurisdiction sufficient to register/enforce the judgment	Diversity jurisdiction existed (amount and citizenship) and could support federal registration/enforcement	Woo failed to plead or timely assert diversity; the theory was raised first on reconsideration and lacked pleaded jurisdictional facts	The motion for reconsideration improperly raised a new, previously available theory; denial was not an abuse of discretion and diversity was not established
Whether Massachusetts statutes could authorize registration/enforcement in federal court	Massachusetts enforcement statutes (Uniform Enforcement of Foreign Judgments Act and execution statute) permit registration in federal court	State procedures cannot supply federal subject‑matter jurisdiction; UEFJA was not in effect when Woo filed; state law applies only if federal jurisdiction exists	Massachusetts law cannot be used to circumvent the absence of federal jurisdiction; state statutes do not create federal jurisdiction

Key Cases Cited

Caballero v. Fuerzas Armadas Revolucionarias de Colombia, 945 F.3d 1270 (10th Cir.) (§1963 does not extend to state judgments)
Mobil Cerro Negro, Ltd. v. Bolivarian Republic of Venezuela, 863 F.3d 96 (2d Cir.) (same conclusion as to §1963’s scope)
Fox Painting Co. v. NLRB, 16 F.3d 115 (6th Cir.) (§1963 limited to specified federal courts)
GE Betz, Inc. v. Zee Co., 718 F.3d 615 (7th Cir.) (held §1963 does not bar federal courts from hearing registration matters when independent jurisdiction exists; did not hold §1963 authorizes registration of state judgments)
Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts are courts of limited jurisdiction; party asserting jurisdiction bears burden)
Bearbones, Inc. v. Peerless Indem. Ins. Co., 936 F.3d 12 (1st Cir.) (requirements for alleging diversity jurisdiction)