Part II of this Comment provides some background on the current American scheme of foreign judgment recognition and enforcement by comparing and contrasting its three major components American common law, the Restatement (Third) of Foreign Relations Law, and the Uniform Foreign Money-Judgments Recognition Act. Part III tracks the English scheme of foreign judgment recognition and enforcement from its common law origin to its more sophisticated and streamlined foreign judgment registration system. Finally, Part IV suggests that the United States could benefit from the implementation of federal legislation that would bring foreign judgment registration procedures to American courts and provide for the recognition and enforcement of foreign judgments on a national level.
Brian Richard Paige, Foreign Judgments in American and English Courts: A Comparative Analysis, 26 SEATTLE U. L. REV. 591 (2003).