Woo v. Spackman, No. 20-1527 (1st Cir. 2021)Annotate this Case
In this appeal concerning the scope and reach of 28 U.S.C. 1963 - a statute permitting the registration of certain judgment in a federal district court - the First Circuit affirmed the district court's judgment concluding that the New York state court judgment proffered by Plaintiff did not come within the statutory sweep and that no other cognizable basis for federal subject-matter jurisdiction had been shown, holding that the district court did not err.
Plaintiff sought recognition of a Korean judgment in New York. A New York court recognized the Korean judgment and entered a judgment in Plaintiff's favor for more than $13 million. When the New York judgment went unpaid, Plaintiff filed the judgment in the United States District Court for the District of Massachusetts. Defendants moved to quash, arguing that the district court lacked subject-matter jurisdiction because 28 U.S.C. 1963 only authorized district courts to register judgments of other federal courts and not state court judgments. The district court agreed and dismissed the matter for want of subject-matter jurisdiction. The First Circuit affirmed, holding (1) section 1963 does not authorize federal courts to register state-court judgments; and (2) there were no independent grounds for federal jurisdiction here.