Hilton v. Guyot

''Hilton v. Guyot'', 159 U.S. 113 (1895), was a United States Supreme Court case where the Court ruled that the recognition and enforceability of a foreign judgment rested on the " comity of nations," namely whether there would be any reciprocity and mutual recognition by the foreign jurisdiction from which the judgment was issued.

''Hilton'' established the fundamental basis for the recognition and enforcement of foreign judgments in the United States, remaining "the most detailed exposition of any American court" on this principle. It is also viewed as the quintessential statement of comity in international law, and is one of the earliest decisions of the U.S. Supreme Court to assert that international law is part of U.S. law.

Background

Hilton and Libbey, U.S. citizens conducting business in Paris, France, were sued in French court by Guyot, the administrator of a French firm, for sums allegedly owed to that firm. They appeared and litigated the merits before the French court, which rendered a judgment against them that was affirmed by a higher court and became final. Guyot sought to enforce that judgment in federal district court in New York, which held that the French judgment was enforceable without retrial on the merits. Hilton and Libbey subsequently appealed to the U.S. Supreme Court.

Opinion of the Court

The central question before the Court was whether a judgment had force beyond the limits of the sovereign jurisdiction from which its authority derived. In finding that there was no applicable treaty or domestic statute from which an answer could be derived, the Court determined that it was incumbent on the judiciary to ascertain the law, based on guidance from "judicial decisions, from the works of jurists and commentators, and from the acts and usages of civilized nations."

In an opinion authored by Justice Horace Gray, the Court, drawing upon both domestic and international legal sources, concluded that whether any foreign judgment was to be enforced in the U.S. rested on whether there was comity between the U.S. and the foreign jurisdiction in question. In articulating this position, the Court set forth the general standard for making this determination and for what defined international comity.

Applying this standard, the Court reasoned, after examining relevant French laws and judicial decisions, that a French court would not have recognized a foreign judgment without having first considered its merits. Therefore, based on the notion of reciprocity derived from international comity, U.S. courts should similarly examine the merits of any judgment prior to ruling on its enforcement. The judgment of the U.S. circuit court was subsequently reversed and the case remanded for retrial.

The Court's opinion is notable for drawing heavily from international legal sources, specifically the laws and practices of over a dozen nations all over the world regarding the recognition and enforcement of foreign judgments. Thus, ''Hilton'' was one of the first Supreme Court cases to apply customary international law—the prevailing practices of states—in making its determination as to non-U.S. judgments:

See also

* Foreign-Country Money Judgments Recognition Act (a 1962 Uniform State Act promulgated by the Uniform Law Commissioners)
*''The'' ''Paquete Habana'', a U.S. Supreme Court decision in 1900, also authored by Justice Gray, that ruled that international law is part of U.S. law.

Notes

External links

*
* {{caselaw source
, case = ''Hilton v. Guyot'', {{Ussc, 159, 113, 1895, el=no
, justia =https://supreme.justia.com/cases/federal/us/159/113/
, loc =http://cdn.loc.gov/service/ll/usrep/usrep159/usrep159113/usrep159113.pdf

1895 in United States case law
United States Supreme Court cases
United States Supreme Court cases of the Fuller Court