This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case arises from a breach of contract dispute. A New Mexico corporation, the Defendant, agreed to purchase a Canadian trade name for $150,000 from the Plaintiffs, two Canadian corporations. The Defendant also agreed to continue purchasing goods from one of the Plaintiffs. The Defendant paid only half of the purchase price, leading the Plaintiffs to file a breach of contract suit in Canada. The Defendant was served in New Mexico but refused to participate in the Canadian proceedings, resulting in a default judgment against it (paras 3, 21).
Procedural History
- Ontario Superior Court of Justice: Issued a default judgment against the Defendant for $75,431.51 in U.S. dollars and $600 in Canadian currency for costs (para 3).
- District Court of Santa Fe County: Domesticated the Canadian judgment under the New Mexico Uniform Foreign Money-Judgments Recognition Act (UFMJRA) (para 3).
Parties' Submissions
- Appellant (Defendant): Argued that the Canadian court lacked personal jurisdiction over it under New Mexico long-arm jurisprudence and that the judgment should not be domesticated under the UFMJRA (para 3).
- Appellees (Plaintiffs): Contended that the Defendant had sufficient contacts with Canada to establish personal jurisdiction and that the judgment was enforceable under the UFMJRA. They also argued that the Defendant waived its jurisdictional objection by failing to appear in the Canadian court (paras 4, 6, 21).
Legal Issues
- Did the Defendant waive its right to contest personal jurisdiction by failing to appear in the Canadian court?
- Did the Canadian court have personal jurisdiction over the Defendant under the UFMJRA?
- Should the Canadian judgment be domesticated and enforced in New Mexico?
Disposition
- The Court of Appeals affirmed the district court's decision to domesticate the Canadian judgment in New Mexico (para 24).
Reasons
Per Vigil J. (Alarid and Kennedy JJ. concurring):
Waiver of Jurisdictional Objection: The Court rejected the Plaintiffs' argument that the Defendant waived its right to contest personal jurisdiction by not appearing in the Canadian court. The Court held that the Defendant preserved the issue by raising it in the New Mexico district court (paras 4-6).
Personal Jurisdiction under UFMJRA: The Court applied New Mexico law to determine whether the Canadian court had personal jurisdiction. It found that the Defendant had sufficient minimum contacts with Canada, including purchasing a Canadian trade name, agreeing to Canadian law governing the contract, and engaging in extensive business dealings with the Plaintiffs in Canada. These contacts satisfied both New Mexico's long-arm statute and due process requirements (paras 10-21).
Recognition of Judgment under Comity: The Court held that the Canadian judgment was entitled to recognition under principles of comity. The Defendant's business dealings with the Plaintiffs, including visits to Canada and ongoing transactions, established sufficient contacts to justify enforcement of the judgment (paras 22-23).
Burden of Proof: The Court clarified that under the UFMJRA, the burden of proof to contest jurisdiction lies with the party opposing domestication, in this case, the Defendant (para 12).
The Court concluded that the Canadian court properly exercised personal jurisdiction and affirmed the district court's order domesticating the judgment (para 24).