This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- In 2010, a Nevada state court issued a judgment against Defendants for $1,584,893. This judgment was registered in California the same year under California's Sister State Money Judgments Act. In May 2020, Plaintiff was assigned the rights to collect on this judgment, and in July 2020, Plaintiff renewed the judgment in California, extending its enforceability for an additional ten years. In November 2020, Plaintiff sought to domesticate and enforce the California judgment in New Mexico and to void a 2017 property transfer by Defendant Mynarcik under the Uniform Voidable Transactions Act (para 2-3).
Procedural History
- District Court of Santa Fe County: Granted Defendants' motion for summary judgment and denied Plaintiff's counter-motion for summary judgment, finding the California judgment could not be domesticated and enforced in New Mexico (para 1).
Parties' Submissions
- Plaintiff: Argued that the California judgment, being a registration of the Nevada judgment, should be recognized and enforced in New Mexico as it is treated as an original California judgment under California law (para 1).
- Defendants: Contended that the California judgment was not entitled to full faith and credit in New Mexico because it was a ministerial registration of an expired Nevada judgment and not a court-rendered personal money judgment (para 3).
Legal Issues
- Whether the California judgment is entitled to full faith and credit under Article IV, Section 1 of the United States Constitution in New Mexico (para 4).
Disposition
- The Court of Appeals of the State of New Mexico reversed the district court's order, determining that the California judgment is entitled to full faith and credit in New Mexico and remanded the matter for enforcement to be decided on the merits (para 15).
Reasons
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Per BOGARDUS, J. (BACA, J., and BUSTAMANTE, J., retired, concurring): The appellate court concluded that the California judgment, as a registered Nevada judgment, is valid and enforceable under both California and New Mexico law. It reasoned that under California law, a registered foreign judgment is treated as an original judgment of California and is entitled to full faith and credit in New Mexico. The court found no New Mexico procedural limitations preventing the domestication of the California judgment. It emphasized that New Mexico courts must give full faith and credit to judgments from other states unless the judgment is void, which was not the case here. The court also noted that the California Supreme Court and the United States Supreme Court denied certiorari on the validity and enforceability of the California judgment, rendering Defendants' motion to dismiss the appeal moot (paras 4-14, [1]).
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