(University of Oregon School of Law, 2017-07-27) Meier, Niklaus
When the recognition of foreign-country judgments is sought in the United States, it occurs that recognition is denied due to lack of jurisdiction. In the United States, jurisdiction of foreign courts is examined according to the same due process requirements of the U.S. Constitution that apply to direct jurisdiction and to the recognition of sister-state judgments. These criteria were developed in a national, federal, interstate context and are not appropriate for claims involving international elements, which necessarily follow jurisdictional concepts differently than the United States does.
