NY Commercial Litigation Report, April 2025 | Vol. 17

It's Nothing Personal: Federal District Court Recognizes English Judgment Against Foreign Debtor Not Subject to Personal Jurisdiction in New York

Southern District of New York: Standing alone, lack of personal jurisdiction was not a viable defense to recognition of a foreign money judgment where the debtor's other defenses were "meritless on their face" or "wholly lacking in evidentiary support."

Cargill Financial Services International Inc. v. Barshchovskiy, 2025 WL 522108 (S.D.N.Y. Feb. 18, 2025).

A two-step process governs the recognition and enforcement of foreign money judgments in New York. First, recognition of a foreign judgment under Article 53 of the New York Civil Practice Law and Rules ("CPLR") essentially converts the foreign judgment into a New York state or federal court judgment. Once recognized, the judgment may then be enforced against the debtor's assets in the jurisdiction in accordance with CPLR Article 52. These distinct steps have