XPX Armor & Equip., Inc. v. SkyLIFE Co., Inc.

Summary

The Sixth District Court of Appeals of Ohio reviewed whether an Ohio court was required to enforce a North Carolina default judgment against an Ohio corporation. The court held that the North Carolina court lacked personal jurisdiction over SkyLIFE because the company lacked sufficient purposeful contacts with North Carolina, and it affirmed the Ohio trial court’s refusal to enforce the judgment. The court also concluded that the foreign judgment could be collaterally attacked as void and that the trial court properly addressed jurisdictional arguments despite the motion’s designation under Civ.R. 60(B).

Holdings

1. An Ohio trial court has inherent authority to vacate a void foreign judgment and is not prevented from addressing jurisdictional arguments merely because the judgment debtor styled its motion as one under Civ.R. 60(B).
2. The alleged agreement to ship parachutes from North Carolina was sufficient to satisfy N.C. Gen. Stat. § 1-75.4(5)(c).
3. North Carolina lacked general personal jurisdiction over SkyLIFE because SkyLIFE was not essentially at home there.
4. North Carolina lacked specific personal jurisdiction over SkyLIFE because XPX failed to make a prima facie showing that SkyLIFE purposefully availed itself of the privilege of acting in North Carolina.
5. The North Carolina default judgment was not entitled to full faith and credit in Ohio because the North Carolina court lacked personal jurisdiction over SkyLIFE, rendering the judgment void and subject to collateral attack.

Questions Presented

1. Whether the Ohio trial court had authority to determine that the domesticated North Carolina judgment was void despite XPX's use of a Civ.R. 60(B) motion.
2. Whether the North Carolina court had personal jurisdiction over SkyLIFE under North Carolina's long-arm statute.
3. Whether exercising specific or general personal jurisdiction over SkyLIFE in North Carolina complied with the Due Process Clause of the Fourteenth Amendment.
4. Whether the North Carolina judgment was entitled to full faith and credit in Ohio.
5. Whether the service-of-process assignments of error were moot after the court concluded that North Carolina lacked personal jurisdiction.

Disposition

affirmed