Friday, December 27, 2013

Hilton v. Guyot case brief

Hilton v. Guyot case brief summary
159 U.S. 113 (1895)

Defendants appealed an order from the Circuit Court of the United States (SDNY), which directed a verdict for plaintiffs in the amount that a French court had awarded.
Defendants alleged fraud on the plaintiff's part.

Plaintiffs sued the defendants in a French court under a contract claim.
The defendants alleged fraud on the (Ps) part, and the (Ds) sought an injunction from bringing suit. The court, however, would not admit evidence and entered a directed verdict for plaintiff.
A French appeals court affirmed the judgment.
Defendants sought review in the United States.

  • The court stated that comity was reciprocal. 
  • Because France did not recognize final judgments of the U.S., and would try such judgments anew, judgements given by France would be given the same treatment. 
  • Therefore, the comity of the United States did not require the court to give conclusive effect to the judgments of the courts of France. 
  • Defendants could be granted a new trial.

The judgment was reversed and the cause was remanded for a new trial.
Comity was not afforded to foreign judgments when the country did not reciprocate comity.

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