Sentinel Acceptance Ltd., L.P. v. Hodson Auto Sales & Leasing, Inc.
Missouri Court of Appeals
45 S.W.3d 464 (Mo. App. 2001)
Sentinel Acceptance (plaintiff) obtained a California arbitration award and confirming judgment against Janet Hodson and her company (defendants), then registered that judgment in Missouri to garnish Hodson's assets; Hodson claimed she was never personally served or informed of the California proceedings, which her husband handled entirely on her behalf without her knowledge, including retaining California counsel who had no direct contact with her. The Missouri trial court quashed registration of the California judgment based on Missouri's rule allowing foreign judgments to be reopened, vacated, or stayed like any Missouri judgment, finding Hodson's lack of knowledge constituted 'surprise'; Sentinel appealed.
Whether a court may quash registration of a foreign state's judgment on the ground of surprise.