The current situation reflects a system for the recognition and enforcement of foreign judgments in the U.S. that is far from uniform or predictable. In general, it is almost impossible to anticipate the procedural or substantive principles that would be applicable to a particular foreign judgment. It is not until the party seeking the enforcement chooses a forum in the U.S. that the particular state law might give a sense of how the case, could be resolved by the state court, or the federal court applying state law. Nevertheless, for any foreign lawyer seeking answers regarding the enforceability of the judgment in the U.S. would definitely find the discussion difficult. It would require consultation with more than one American lawyer, a review of state law, and an analysis of any legislation at the local level before there could be a sensible response on the status that the foreign judgment could have in the U.S.
