Greenfield Advisors, LLC v. Salas
Greenfield Advisors, LLC v. Salas
Opinion of the Court
This appeal challenges the ruling to give full faith and credit to two judgments rendered by the United States District Court for the Western District of Washington (Federal District Court). For the reasons that follow, we affirm.
The Appellee, Greenfield Advisors, LLC (Greenfield) is a Seattle-based company. The Appellants contracted with Greenfield to provide consulting services for various legal cases.
The arbitrator awarded Greenfield $331,316.48, plus pre-award interest of $163,514.79, and post-award interest at 18%. Greenfield filed a motion with the Federal District Court to confirm the award. The Appellants again raised a jurisdictional argument that was denied and the Federal District Court confirmed the award and rendered judgment.
Next, Greenfield filed an Ex-Parte Petition to Make Foreign Judgments Executory in Civil District Court for the Parish of Orleans (State District Court) pursuant to the Uniform Enforcement of Foreign Judgments Act, La. R.S. 13:4241 et seq. In response to the Petition, the Appellants filed several exceptions and a motion requesting the State District Court to deny full faith and credit of the Federal District Court judgments. The State District Court held a hearing on the Appellants' exceptions, motion to deny full faith and credit, and Greenfield's petition to make the judgments executory. After hearing the arguments of the parties, the State District Court denied the exceptions, denied the Appellants' motion and granted full faith and credit to the judgments. This appeal followed.
On appeal, the Appellants argue that the State District Court erred in giving full faith and credit to the judgments rendered by the Federal District Court because the Federal District Court lacked subject matter and personal jurisdiction. The Appellants further maintain that the State District Court was required to address the merits of the jurisdictional argument prior to granting full faith and credit to the judgments. We disagree.
It is well settled that the Full Faith and Credit Clause, Article IV, Section 1, of the Constitution of the United States, mandates that judgments have the same credit, validity, and effect in every other state of the United States that it has in the state where it is pronounced.
Although the Appellants insist that Schultz requires a hearing on the merits of the foreign court's jurisdiction or lack thereof, the inquiry that is required is merely a determination " 'that those questions [as to jurisdiction] have been fully and fairly litigated and finally decided in the court which rendered the original judgment." '
AFFIRMED
The Appellants are Camilo Salas, III and his law firm Salas & Co., L.C. Although Mr. Salas argues that he did not enter into any agreement with Greenfield in his individual capacity, he is named in the judgment.
There was also a judgment entered for attorneys' fees in the amount of $12,000.00.
Schultz v. Doyle, 00-926, p. 9 (La. 1/17/01),
Schultz, p. 10,
Schultz,
The trial court and the court of appeal denied giving full faith and credit to the judgment. The Louisiana Supreme Court granted a writ of certiorari and reversed.
Schultz, p. 10,
Case-law data current through December 31, 2025. Source: CourtListener bulk data.