Midbrook Flowerbulbs Holland v. Holland America Bulb Farms, No. 14-36085 (9th Cir. 2017)
Annotate this CaseMidbrook filed suit seeking recognition of an Amsterdam Court of Appeals judgment under Washington's Uniform Foreign-Country Money Judgments Recognition Act (UFCMJRA). The Ninth Circuit affirmed summary judgment for Midbrook and denied Holland America's discovery request under Federal Rule of Civil Procedure 56(d). The panel held that the commentary and prefatory note to the UFCMJRA demonstrate that under section 4(c)(8), courts ask only whether the party resisting judgment "was denied fundamental fairness in the particular proceedings leading to the foreign-country judgment," not whether the foreign proceedings literally conformed to the requirements of due process under our own Constitution. UFCMJRA 4 cmt. 12. The panel explained that it was not necessary to decide whether process accorded to Midbrook also passed muster under American standards of due process. The panel held that the Dutch courts' treatment of Holland America's discovery requests was a mere "procedural difference" that was insufficient to establish that the Dutch proceedings were fundamentally unfair; Holland America was not denied due process when the Amsterdam Court of Appeal overturned the Alkmaar District Court's factual finding denying the existence of the parties' alleged 1999 settlement agreement; and the district court did not abuse its discretion in denying Holland America's motion for additional discovery.
Court Description: Uniform Foreign-Court Money Judgments Recognition Act The panel affirmed the district court’s order granting summary judgment in favor of Midbrook Flowerbulbs Holland B.V., and denying Holland America Bulb Farms, Inc.’s discovery request under Fed. R. Civ. P. 56(d), in Midbrook’s diversity action seeking recognition of an Amsterdam Court of Appeals judgment under Washington’s Uniform Foreign-Country Money Judgments Recognition Act (“UFCMJRA”). Holland America, a Washington company, purchased flower bulbs from Midbrook, a Dutch company, and Midbrook obtained a judgment against Holland America in Dutch court. On appeal, Holland America alleged that proceedings in the Dutch courts which led to the Dutch judgment were “not compatible with the requirements of due process of law” under section 4(c)(8) of the UFCMJRA. Concerning the legal standard governing the issue at hand, the panel held that the commentary and prefatory notice to the UFCMJRA demonstrated that under section 4(c)(8), courts need ask only whether the party resisting judgment “was denied fundamental fairness in the particular proceedings leading to the foreign-country judgment,” not whether the foreign proceedings literally conformed to the requirements of due process under the U.S. Constitution.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.