City of Oakland v. Desert Outdoor Adver.

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Justia Opinion Summary

A California district court found that Desert Outdoor Advertising engaged in unlawful business practices through its violation of city ordinances prohibiting Desert Outdoor's erection of an outdoor billboard. The court imposed civil statutory penalties on Desert Outdoor and entered a civil judgment in favor of the city. The city filed its California judgment in a Nevada district court, seeking enforcement of the judgment under the Uniform Enforcement of Foreign Judgments Act. Desert Outdoor then filed a motion to set aside the foreign judgment and quash execution of the judgment. The district court granted Desert Outdoor's motion, concluding that because California's judgment was penal, it was not entitled to full faith and credit. On appeal, the Supreme Court affirmed, holding that the California judgment in this case was penal in nature, and as such, was not enforceable in Nevada under Huntington v. Attrill, which provides an exemption to the Full Faith and Credit Clause such that other states' penal judgments are unenforceable in Nevada.

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