Monks Own, Limited, and St. Benedictine Biscop Benedictine Corporation v. Monastery of Christ in the Desert

Summary

The New Mexico Supreme Court addressed the recognition and domestication of a Canadian money judgment under the New Mexico Uniform Foreign Money-Judgments Recognition Act. It held that the enforcing court first determines personal jurisdiction under the foreign jurisdiction's law and then evaluates whether the jurisdictional basis satisfies American due process standards. The court affirmed domestication, concluding that the Monastery had sufficient minimum contacts with Canada.

Holdings

1. A party need not raise a personal-jurisdiction objection in the foreign proceeding to preserve the issue for review in a New Mexico proceeding seeking recognition of the foreign judgment; the objection may be raised in response to the domestication petition.
2. When one of the six jurisdictional circumstances listed in NMSA 1978, Section 39-4B-6(A), is present, New Mexico law, specifically the UFMJRA, governs and the enforcing court need not inquire further.
3. When none of Section 39-4B-6(A)'s enumerated circumstances applies, the enforcing court must first determine whether the foreign court had personal jurisdiction under the foreign jurisdiction's law and then determine whether that jurisdictional basis satisfies American constitutional due-process standards.
4. The Monastery had sufficient minimum contacts with Canada to satisfy American due-process principles, and the Canadian judgment was therefore recognizable under the UFMJRA.

Questions Presented

1. Whether a New Mexico court applying the UFMJRA should use Canadian law or New Mexico law to determine whether the Canadian court had personal jurisdiction over the Monastery.
2. Whether the Monastery had sufficient contacts with Canada to satisfy American constitutional due process standards for personal jurisdiction under the UFMJRA's other-bases-of-jurisdiction provision.
3. Whether the Monastery was required to raise its personal-jurisdiction objection in the Canadian proceeding to preserve the issue in the New Mexico domestication proceeding.

Disposition

affirmed