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Case Citations [i] (Fall 2025)

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                         THE AMERICAN


                           LAW INSTITUTE



                                  Fall 2025 Citations



      THE FOREIGN RELATIONS LAW OF THE

  UNITED STATES 4TH: SELECTED TOPICS IN

  TREATIES, JURISDICTION, AND SOVEREIGN

                                IMMUNITY



           PART  IV. JURISDICTION,  STATE  IMMUNITY,   AND JUDGMENTS

                            CHAPTER   2. ADJUDICATION

            SUBCHAPTER   A. JURISDICTION TO ADJUDICATE   IN CIVIL CASES

§ 422. Personal Jurisdiction

Wash.App.2024. Com. (a) quot. in ftn. Irish judgment creditor filed an action against Indian judgment
debtor, seeking the recognition of a foreign money judgment that it obtained in an English court for
debtor's failure to pay creditor for the rental of two aircraft. The trial court denied debtor's motion to
dismiss for lack of personal jurisdiction under the Uniform Foreign-Country Money Judgments
Recognition Act. This court affirmed, holding, as a matter of first impression, that a creditor was not
required to establish a basis for the exercise of personal jurisdiction over a debtor before obtaining
recognition of a foreign judgment under the Act. The court cited Restatement Fourth of Foreign
Relations Law of the United States: Selected Topics in Treaties, Jurisdiction, and Sovereign Immunity §
422 in pointing out that it generally referred to personal jurisdiction instead of the traditional
categories-including in personam, in rem, and quasi in rem jurisdiction-because the specific
distinctions between them had only modest analytic utility in the modern context. Alterna Aircraft V.B.
Ltd. v. SpiceJet Ltrd., 559 P.3d 1026, 1029.






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