Many nations do not accord conclusive effect to foreign judgments unless their own judicial decrees are reciprocally enforced by the country rendering the judgment. The law in the United States is unsettled, with some states holding that foreign judgments are reviewable on the merits if the judgment forum similarly reviews the merits of American decrees, while others accord conclusive effect to valid foreign money judgments regardless of the effect accorded American decrees in the judgment forum. Judgments in the latter states would seem entitled to conclusive enforcement in countries requiring reciprocity. However, such conclusive recognition has been hindered because many civil-law courts tend to look solely to the legislation of other countries in determining the treatment accorded there to foreign judgments, and few states in the United States have enacted recognition legislation. Some civil-law courts are therefore inclined to conclude, often erroneously, that a state does not enforce foreign judgments, and thus does not meet the reciprocity requirement, if there is no recognition legislation in that state.
Michigan Law Review,
The Uniform Foreign Money-Judgments Recognition Act,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol64/iss2/8