Standard Chartered Bank v. Ahmad Hamad , 99 A.3d 936 ( 2014 )

J.A13031/14
2014 Pa. Super. 179
STANDARD CHARTERED BANK, : IN THE SUPERIOR COURT OF
: PENNSYLVANIA
Appellee :
:
v. :
:
:
AHMAD HAMAD AL GOSAIBI AND :
BROTHERS COMPANY, ET AL., :
:
Appellants : No. 2406 EDA 2013
Appeal from the Order Entered July 16, 2013
In the Court of Common Pleas of Philadelphia County
Civil Division No(s).: 130301427
BEFORE: ALLEN, MUNDY, and FITZGERALD,* JJ.
OPINION BY FITZGERALD, J.: FILED AUGUST 20, 2014
Ahmad Hamad Al Gosaibi and Brothers Co., et al.
from the order entered in the Philadelphia County Court of Common Pleas
denying its motion to vacate judgment in favor of Standard Chartered Bank
w York judgment
recognizing a Bahraini money judgment in favor of Standard Chartered. We
judgment is entitled to full faith and credit in Pennsylvania. Accordingly,
*
Former Justice specially assigned to the Superior Court.
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because Standard Chartered sought to enforce a valid New York judgment in
Pennsylvania, we affirm.
Standard Chartered is a banking corporation organized under the laws
of England and Wales with a New York branch. AHAB is a Saudi Arabian
partnership whose partners are all citizens and residents of Saudi Arabia. In
April 2009, the parties entered into a currency exchange agreement wherein
Standard Chartered agreed to sell Saudi Riyals to AHAB in exchange for
United States Dollars. Standard Chartered transferred the Riyals
account, but AHAB did not transfer the corresponding Dollars to Standard
twenty-five million dollar money judgment, plus interests and costs, against
AHAB in the Bahrain Chamber for Dispute Resolution, a commercial court of
the Kingdom of Bahrain.1 AHAB did not exercise its right to appeal from the
Bahraini judgment in favor of Standard Chartered.
In December 2011, Standard Chartered commenced an action against
AHAB in the Supreme Court2 of the State of New York, New York County, to
1
For additional background, see Ahmad Hamad Algosaibi & Bros. Co. v.
, 785 F. Supp. 2d 434 (S.D.N.Y
2011), and In re Certain Funds, Accounts, and/or Inv. Vehicles
Managed by Affiliates of Fortress Inv. Grp LLC, No. 14 Civ. 1801, 2014
WL 3404955, 2014 U.S. Dist. LEXIS 95578 (S.D.N.Y. July 9, 2014).
2
In New York, the Supreme Court is the trial court of general jurisdiction,
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of the Uniform Foreign Money Judgment Recognition Act3
rd Chartered cross-
moved for summary judgment. Before the New York court, AHAB argued
that the trial court should refuse to recognize the Bahraini judgment,
denied fundamental due process in the Bahraini tribunal and because
Bahrain was an inconvenient forum. On December 12, 2012, after a full
hearing and briefing, the New York court granted summary judgment in
favor of Standard Chartered. On January 28, 2013, judgment was entered
in favor of Standard Chartered in the amount of $27,207,4004 against
AHAB.5, 6
3
See N.Y. C.P.L.R. 5301-09 (McKinney 2014) (Uniform Recognition of
Foreign Country Money Judgments Act).
4
This amount reflects the twenty-five million dollar judgment in favor of
Standard Chartered, plus interest, costs, and disbursements, as calculated
by the New York court.
5
See Standard Chartered Bank v. Ahmad Hamad Al Gosaibi & Bros.
Co., 38 Misc. 3d 831, 957 N.Y.S.2d 602 (N.Y. Sup. Ct. 2012).
6
On September 24, 2013, the New York court issued an order quashing
duces tecum and information subpoenas
based upon a finding that it lacked personal jurisdiction over AHAB pursuant
-arm statute, N.Y. C.P.L.R. 302 (McKinney 2014).
However, the New York court did not disturb its December 12, 2012 order
recognizing the Bahraini judgment.
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which unanimously affirmed the trial court on October 24, 2013.7 On April
22, 2014, the intermediate appell
8
Meanwhile, on March 11, 2013, Standard Chartered filed the New York
judgment in the Philadelphia County Court of Common Pleas pursuant to the
Uniform Enforcement of Foreign Judgments Act9 10
On
April 19, 2013, AHAB filed a motion to vacate the judgment. On May 13,
2013, Standard Chartered filed an answer to the motion to vacate. After
further briefing by both parties and a full hearing on the matter, the trial
7
See Standard Chartered Bank v. Ahmad Hamad Al Gosaibi & Bros.
Co., 110 A.D.3d 578, 973 N.Y.S.2d 197 (N.Y. App. Div. 2013), pet. for leave
to appeal denied, No. 10869, 653506/11 (N.Y. App. Div. Apr. 22, 2014).
8
See Standard Chartered Bank v. Ahmad Hamad Al Gosaibi & Bros.
Co., No. 10869, 653506/11 (N.Y. App. Div. Apr. 22, 2014). This case has
-judgment
discovery.
9
42 Pa.C.S. § 4306.
10
In February 2013, Standard Chartered also filed for enforcement of the
New York judgment in the trial court of Washington, D.C. pursuant to
See D.C. Code § 15-352
(2014). AHAB moved to set aside that judgment, arguing that the District of
Columbia court could not register the Bahraini judgment unless it
Act. The District of Columbia court disagreed, reasoning that full faith and
credit principles permitted enforcement of Standard Chartere
York judgment. See Standard Chartered Bank v. Ahmad Hamad Al
Gosaibi & Bros. Co., No. 2013 CA 001602F (D.C. Super. Ct. May 22,
listed for oral argument on April 10, 2014. Its disposition is pending.
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2013, concluding
[h]ere, the mandates of the United States Constitution,
clear. The New York judgment is entitled to full faith and
credit just as any other judgment issued by a New York
court. [AHAB] had a full and fair opportunity to litigate
whether the Bahraini judgment should be entered pursuant
nition Act]. [Standard
Chartered] duly filed the New York judgment in
Pennsylvania pursuant to 42 Pa.C.S. § 4306. Therefore,
the New York judgment is entitled to the same res judicata
effect it would have in New York. Therefore, it is of no
moment whether Pennsylvania would have recognized the
because here, [Standard Chartered] is seeking to enforce a
New York judgment, not a direct Bahraini judgment.
Trial Ct. Op., 10/9/13, at 8 (some capitalization omitted). This timely appeal
followed.11
AHAB raises the following issues on appeal:
Did the trial court err, when by order docketed on July 16,
judgment?
Did the trial court err in denying the petition because, as a
matter of sound public policy and of law, full faith and
credit does not preclude a state from applying its own
statutory law and policies to the question of recognition of
a foreign country judgment simply because a party has
chosen to obtain recognition of that judgment in another
state first, as a different rule would promote forum-
shopping and undermine important interests of states in
applying their own recognition standards and policies to
foreign country judgments?
11
Both AHAB and the trial court have complied with Pa.R.A.P. 1925.
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To the extent its denial of said petition was based on a
conclusion that full faith and credit principles mandated
recognition of the Bahraini judgment (since New York
previously recognized the judgment as enforceable in that
state), did the trial court err in rejecting or failing to
required to give full faith and credit to the New York
decision, and was not precluded from applying
of recognition and enforcement of the underlying Bahraini
judgment?
Did the trial court err in permitting [Standard Chartered]
version of the [Enforcement Act] improperly to obtain
recognition in Pennsylvania of a Bahraini judgment, which
the trial court should have subjected to more searching
version of the [Recognition Act]?
-4 (capitalization omitted).
t the trial court erred in
affording full faith and credit to the New York judgment in favor of Standard
Chartered. Id. at 18. In support of this argument, AHAB makes two
primary claims. First, AHAB opines the New York judgment is not entitled to
full f Id.
at 20. Next, AHAB hypothesizes that even if the judgment is entitled to full
faith and credit, Pennsylvania may abrogate the full faith and credit mandate
by subjecting Standard Charter
the Recognition Act in order to ascertain whether recognition of the
Id. at 20, 22-27, 31-
33. Simply, AHAB insists a Pennsylvania court can ignore full faith and
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entitled to relief.
We review the denial of a petition to vacate a foreign judgment for an
abuse of discretion or error of law. Olympus Corp. v. Canady, 962 A.2d
671, 673-74 (Pa. Super. 2008).
raises a question of law. Id.
standard of review is de novo
Id. (citation omitted).
When interpreting statutes, this Court is guided by the following
principles:
The goal in interpreting any statute is to ascertain and
effectuate the intention of the General Assembly. Our
Supreme Court has stated that the plain language of a
statute is in general the best indication of the legislative
intent that gave rise to the statute. When the language is
clear, explicit, and free from any ambiguity, we discern
intent from the language alone, and not from the
statute. We must construe words and phrases in the
statute according to their common and approved usage.
We also must construe a statute in such a way as to give
effect to all its provisions, if possible, thereby avoiding the
need to label any provision as mere surplusage.
Id. at 674 (citation omitted).
be given in each State to the public Acts, Records, and judicial Proceedings
ngress codified the full
faith and credit clause by enacting the Full Faith and Credit Act, 28 U.S.C. §
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have the same full faith and credit in every court within the United States
and its Territories and Possessions as they have by law or usage in the
U.S.C. § 1738.
As explained by the United States Supreme Court,
[t]he very purpose of the full-faith and credit clause was to
alter the status of the several states as independent
foreign sovereignties, each free to ignore obligations
created under the laws or by the judicial proceedings of
the others, and to make them integral parts of a single
nation throughout which a remedy upon a just obligation
might be demanded as of right, irrespective of the state of
its origin.
Milwaukee Cnty. v. M.E. White Co., 296 U.S. 268, 276-77, 56 S. Ct. 229,
234, 80 L. Ed. 220, 228 (1935). Thus, the Full Faith and Credit Act
Matsushita Elec. Indus. Co. v. Epstein, 516 U.S. 367, 373, 116 S. Ct.
873, 877, 134 L. Ed. 2d 6, 17 (1996).
Regarding judgments, however, the full faith and credit
obligation is exacting. A final judgment in one State, if
rendered by a court with adjudicatory authority over the
subject matter and persons governed by the judgment,
qualifies for recognition throughout the land. For claim
and issue preclusion (res judicata) purposes, in other
words, the judgment of the rendering State gains
nationwide force. . . .
We are aware of [no] considerations of local policy or law
which could rightly be deemed to impair the force and
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effect which the full faith and credit clause and the Act of
Congress require to be given to [a money] judgment
outside the state of its rendition.
Baker ex rel. Thomas v. Gen. Motors Corp., 522 U.S. 222, 233-34, 118
S. Ct. 657, 663-64, 139 L. Ed. 2d 580, 592-93 (1998) (alterations in
original) (footnote, citations, and internal quotation marks omitted).
res judicata effect the
judgment would have been afforded in the state in which i
Wilkes ex rel. Mason v. Phoenix Home Life Mut. Ins. Co., 587 Pa. 590,
607, 902 A.2d 366, 376 (2006) (citations omitted) (holding judgment
approving settlement of New York class action had res judicata effect and
was entitled to full faith and credit); see also Morris Lapidus Assocs. v.
Airportels, Inc., 240 Pa. Super. 80, 82, 361 A.2d 660, 662 (1976)
12
Once a
relitigation in other states of
Sutton v. Lieb, 342 U.S. 402, 407, 72 S.
Ct. 398, 402, 96 L. Ed. 448, 455 (1952).
Full faith and credit is statutorily enshrined in
Enforcement Act, which states:
12
We acknowledge Morris Lapidus
the Enforcement Act.
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(b) Filing and status of foreign judgments. A copy of
any foreign judgment including the docket entries
incidental thereto authenticated in accordance with act of
Congress or this title may be filed in the office of the clerk
of any court of common pleas of this Commonwealth. The
clerk shall treat the foreign judgment in the same manner
as a judgment of any court of common pleas of this
Commonwealth. A judgment so filed shall be a lien as of
the date of filing and shall have the same effect and be
subject to the same procedures, defenses and proceedings
for reopening, vacating, or staying as a judgment of any
court of common pleas of this Commonwealth and may be
enforced or satisfied in like manner.
* * *
(f) Definition.
means any judgment, decree, or order of a court of the
United States or of any other court requiring the payment
of money which is entitled to full faith and credit in this
Commonwealth.
42 Pa.C.S. § 4306(b), (f) (emphasis added).
Hilkmann v. Hilkmann,
579 Pa. 563, 573, 858 A.2d 58, 65 (2004). In Noetzel v. Glasgow, Inc.,
338 Pa. Super. 458, 487 A.2d 1372 (1985), the Superior Court examined
the effect of the full faith and credit clause of the Constitution of the United
States on foreign judgments. The Noetzel Court considered a petition to
strike or open a West Virginia judgment transferred to the Montgomery
County Court of Common Pleas pursuant to the Enforcement Act. Id. at
463, 487 A.2d at 1374. After review, this Court held that judgments
entered in sister states are
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entitled to full faith and credit in Pennsylvania so long as
there was jurisdiction by the court which originally
awarded the judgment, and the defendant had an
opportunity to appear and defend. The courts in
Pennsylvania will refuse to give full faith and credit to a
foreign judgment if it was obtained in derogation of a
basic, due process right of the defendant. However, when
the court of another state has purported to act on the
merits of a case, its jurisdiction to do so and the regularity
of its proceedings are presumptively valid. The party
challenging the validity of the judgment, therefore, bears
the burden of showing any irregularity in the proceedings.
Id. at 465-66, 487 A.2d at 1375-76 (citations omitted).
Generally, Pennsylvania enforces a valid sister-state judgment
transferred to Pennsylvania even if the judgment violates Pennsylvania
public policy. Greate Bay Hotel & Casino, Inc. v. Saltzman, 415 Pa.
Super. 408, 414, 609 A.2d 817, 820 (1992) [hereinafter Greate Bay]. In
Greate Bay, the plaintiff commenced an action against the defendant in
New Jersey to recover unpaid gambling debts. Id. at 410, 609 A.2d at 818.
The defendant failed to appear to defend against the action and a default
judgment was entered against him. Id. The plaintiff then filed the New
Jersey judgment in the Philadelphia County Court of Common Pleas pursuant
to the Enforcement Act. Id. In Pennsylvania, the defendant filed a petition
to open the judgment alleging that he had not received notice of the default
because gambling
debts were violative of public policy and not recoverable in Pennsylvania
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13
Id. The Greate Bay Court held that the
[a] state is required to give full faith and credit to a money
judgment rendered in a civil suit by a sister state even
where the judgment violates the policy or law of the forum
where enforcement is sought. If the judgment was valid
and enforceable in the rendering state, it is equally so in
all other states. Thus, a transferred judgment cannot be
stricken or opened simply because the party seeking to
open or strike can demonstrate that he/she would have a
valid defense to the action if brought in Pennsylvania.
Id. at 414, 609 A.2d at 820 (citations and formatting omitted). To reiterate,
the Enforcement Act addresses valid sister-state judgments only. Id.; see
also Hilkmann
the courts of foreign nations).
13
The statute states:
§ 2031 Gaming contracts to be void.
If any person or persons shall lose any money or other
valuable thing, at or upon any match of cock-fighting,
bullet-playing or horseracing, or at or upon any game of
address, game of hazard, play or game whatsoever, the
person or persons who shall lose their money or other
valuable thing shall not be compelled to pay or make good
the same; and every contract, note, bill, bond, judgment,
mortgage, or other security or conveyance whatsoever,
given, granted, drawn or entered into for the security or
satisfaction of the same, or any part thereof, shall be
utterly void and of none effect.
73 P.S. § 2031.
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Recognition of judgments entered in foreign nations is governed by
[a]ny governmental unit other than the United States, or
any state . . . thereof
denying recovery of a sum of money, other than a judgment for taxes, a fine
or other penalty, or a judgment in matrimonial or famil Id. A
foreign judgment meeting the requirements of the Recognition Act is
nation judgment is
Recognition Act, it is entitled to full faith and credit by our sister states.
As discussed supra, AHAB argues that Pennsylvania erred in giving full
faith and credit to a New York judgment recognizing a Bahraini judgment.
of Standard Chartered has passed appellate scrutiny in that state. 14 See
Standard Chartered Bank, No. 10869, 653506/11 (N.Y. App. Div. Apr. 22,
2014). Furthermore, the court in Washington, D.C., has also permitted
14
duces tecum and
information subpoenas based upon a finding that it lacked personal
jurisdiction did not disturb its December 12, 2012 order recognizing the
Bahraini judgment.
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enforcement of the New York judgment. See Standard Chartered Bank,
No. 2013 CA 001602F (D.C. Super. Ct. May 22, 2013). Therefore, just like
in Greate Bay and Noetzel, in which the plaintiffs possessed valid and
enforceable sister-state judgments, in the instant case, Standard Chartered
possesses a valid New York judgment. See Greate Bay, 415 Pa. Super. at
414, 609 A.2d at 820; Noetzel, 338 Pa. Super. at 465-66, 487 A.2d at
1375-76. Pursuant to the U.S. Constitution, the Full Faith and Credit Act,
matter of law, entitled to full faith and credit in Pennsylvania as with any
other judgment issued by a New York court.15 See U.S. Const. art. IV, § 1;
28 U.S.C. § 1738; Baker, 522 U.S. at 233-34, 118 S. Ct. at 663-64, 139 L.
Ed. 2d at 592-93; Wilkes, 587 Pa. at 607, 902 A.2d at 376; Greate Bay,
415 Pa. Super. at 414, 609 A.2d at 820; Noetzel, 338 Pa. Super. at 465-66,
487 A.2d at 1375-76. That the New York judgment recognized a foreign
nation judgment is of no moment. Just as Pennsylvania courts were
compelled to recognize a New Jersey judgment in Greate Bay and a West
Virginia judgment in Noetzel pursuant to full faith and credit, we are
similarly bound to recognize the instant New York judgment. See Greate
Bay, 415 Pa. Super. at 414, 609 A.2d at 820; Noetzel, 338 Pa. Super. at
15
To the extent AHAB has argued that the language of the Full Faith and
Credit Act, the Enforcement Act, and the Recognition Act is ambiguous, we
discern no ambiguity. Accordingly, we give effect to the plain language of
the statutes. Olympus, 962 A.2d at 673-74.
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465-66, 487 A.2d at 1375-76. Accordingly, the trial court did not err in
giving full faith and cred
plea to disregard full faith and credit and vacate the Pennsylvania judgment.
See, e.g., Baker, 522 U.S. at 233-34, 118 S. Ct. at 663-64, 139 L. Ed. 2d
at 592-93.
AHAB alternatively claims that it is against public policy to permit
Pennsylvania courts to enforce a sister-state judgment using the mechanical
New York judgment recognized a foreign country judgment pursuant to New
Yor
the plain statutory language of the Enforcement Act and examine
cal filing principles could
promote forum-
no relief.
In support of this argument, AHAB relies primarily on Reading &
Bates Constr. Co. v. Baker Energy Res. Corp., 976 S.W.2d 702 (Tex.
App. 1998) [hereinafter Reading]. In Reading, the plaintiff obtained a
judgment against the defendant in Canada. Id. at 705. The plaintiff then
Id. The plaintiff subsequently filed for enforcement of the Louisiana
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that Texas should give full faith and credit to the Louisiana judgment. Id.
The plaintiff also filed to have the underlying Canadian judgment recognized
Id.
The Reading Court, relying on Tanner v. Hancock, 5 Kan. App. 2d
558, 619 P.2d 1177 (Kan. Ct. App. 1980), suggested that to permit
enforcement of the Louisiana judgment would allow the plaintiff to enforce
Reading, 976 S.W.2d at
715. The Reading
the [Enforcement Act] to
16
Id. at 714.
For three reasons, we respectfully disagree with the Reading
quixotic reliance on Tanner.17 First, Tanner did not involve a foreign
country judgment. Tanner addressed a Kansas judgment that had been
Tanner, 5 Kan. App. 2d at 558, 619
P.2d at 1178. The instant case involves a Bahraini judgment. Second, the
Court of Appeals of Kansas held that the Missouri judgment would not be
16
The Texas Court of Appeals, however, did hold that the Canadian
judgment was entitled to recognition under the Recognition Act. Reading,
976 S.W.2d at 712.
17
Regardless, decisions of our sister states are not binding on this Court.
Albert v. Erie Ins. Exch., 65 A.3d 923, 929 (Pa. Super. 2013).
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reason for the entire exercise was to avoid a motion for relief pending in the
ori Reading, 976 S.W.2d at 714 (citing Tanner, 5 Kan. App.
2d at 562-63, 619 P.2d at 1181). There is no allegation or evidence in the
instant matter that Standard Chartered proceeded with any such improper
purpose. Third, Texas has adopted the Uniform Foreign Money Judgments
-law based
recognition law. Compare Tex. Civ. Prac. & Rem. Code. Ann. §§ 36.001-
36.008 (West 2013), with La. Code Civ. Proc. Ann. art 2541(A) (2014), and
Baker & McKenzie Advokatbyra v. Thinkstream Inc., 20 So. 3d 1109,
to enforce a judgment rendered in a foreign country by filing an ordinary
18
action in accordance with LSA-C.C.P. art. 2541 Instantly, the
18
Article 2541 states in pertinent part:
Art. 2541. Execution of foreign judgments
A. A party seeking recognition or execution by a Louisiana
court of a judgment or decree of a court of the United
States or a territory thereof, or of any other state, or of
any foreign country may either seek enforcement pursuant
to R.S. 13:424
Enforcement Act], or bring an ordinary proceeding against
the judgment debtor in the proper Louisiana court, to have
the judgment or decree recognized and made the
judgment of the Louisiana court.
La. Code Civ. Proc. Ann. art. 2541(A) (2014).
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versions of the Recognition Act at issue here
are materially identical. Compare N.Y. C.P.L.R. 5301-09, with 42
P.S. §§ 22001-09. Simply stated, in Pennsylvania, judgments recognized as
valid after a full hearing in a sister-state are res judicata.19, 20
Baker, 522
U.S. at 233-34, 118 S. Ct. at 663-64, 139 L. Ed. 2d at 592-93.; Wilkes, 587
Pa. at 607, 902 A.2d at 376.
To the extent that AHAB asks this Court to hold that, in the interest of
Pennsylvania public policy, the trial court should be required to subject a
New York judgment to
heightened scrutiny and conduct an independent inquiry into the validity of
19
We note also that Reading is apparently the only case in which a court
has refused to adhere to the Full Faith and Credit Clause and denied
enforcement of a sister-state judgment recognizing a foreign judgment. See
Gregory H. Schill, Ending Judgment Arbitrage: Jurisdictional Competition and
the Enforcement of Foreign Money Judgments in the United States, 54
20
AHAB also cites Wamsley v. Nodak Mut. Ins. Co., 341 Mont. 467, 178
P.3d 102 (Mont. 2008), and Matusevitch v. Telnikoff, 877 F. Supp. 1
(D.D.C. 1995), , 159 F.3d 636 (D.C. Cir. May 5, 1998) (per curiam), to
bolster its argument. These cases, too, are distinguishable from the instant
case. First, Wamsley did not concern a foreign country money judgment,
but rather a North Dakota declaratory judgment. Wamsley, 341 Mont. at
481, 178 P.3d at 113. Second, the holding in Matusevitch arose from an
entirely different procedural posture. The Matusevitch court was
considering whether the plaintiff was required to seek recognition of a
Recognition Act before the judgment could be enforced. Matusevitch, 877
F. Supp. at 3. That court was not asked to consider enforcement of a
foreign country money judgment that had already been recognized in a
sister state.
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the New York judgment, AHAB is not entitled to relief. As the trial court
due judgments Baker, 522 U.S. at 233, 118
S. Ct. at 664, 139 L. Ed. 2d at 592 (emphasis in original)). States must give
full faith and credit to sister-
violates See
Greate Bay, 415 Pa. Super. at 414, 609 A.2d at 820. Just as Pennsylvania
enforced a gambling debt that violated public policy in Pennsylvania, even if
the underlying judgment in this case violated our public policy, we are
obliged to enforce it.21 See id.; accord Baker, 522 U.S. at 233, 118 S. Ct.
at 664, 139 L. Ed. 2d at 592.
For all of the foregoing reasons, having discerned no abuse of
discretion or error of law, we affirm the order of the trial court denying
See
Olympus, 962 A.2d at 673.
Order affirmed.
21
the instant case is the application of the Full Faith and Credit Clause as a
cornerstone of our federal system. Milwaukee Cnty., 296 U.S. at 276-77,
56 S. Ct. at 234, 80 L. Ed. at 228.
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Judgment Entered.
Joseph D. Seletyn, Esq.
Prothonotary
Date: 8/20/2014
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