South-Western Legal Studies in Business

Court Has Jurisdiction Over Property Located in State Needed to Enforce Judgment from Other state
Description Appeals court held that courts in the state have jurisdiction over property owned by a foreign corporation that is located within the state. That property may be attached by the court to help enforce a valid judgment against the corporation from another state.
Topic Court Procedure
Key Words Judgment; Enforcement; Full Faith and Credit; Quasi in Rem Jurisdiction; Foreign Business
C A S E   S U M M A R Y
Facts Inno-Pacific is a Singapore corporation with its principal place of business in Singapore. It hired Koh to conduct business activities for it in California. Later, Koh sued Inno-Pacific in California for wrongful termination and received a judgment for $240,000, which Inno-Pacific did not pay. Koh learned that Inno-Pacific owned half interest in Sawyer Falls, a LLC registered in Washington, but with principal place of business in Malaysia. Sawyer Falls owns real estate in Washington. Koh sought an order in state court in Washington to attach Inno-Pacific's interest Sawyer Falls, but Inno-Pacific got the motion quashed based on a lack of personal jurisdiction and lack of in rem jurisdiction in Washington. Koh appealed.
Decision

Reversed. Washington courts have jurisdiction over the LLC. Hence, under the Full Faith and Credit Clause, the court could enforce the judgment against Inno-Pacific's interest in the LLC. The California judgment is valid and will be enforced by Washington courts. While Washington courts have no jurisdiction over the original litigation, they have quasi in rem jurisdiction over the property that can be attached to help enforce a valid judgment.

Citation Koh v. Inno-Paficif Holdings, Ltd., 54 P.3d 1270 (Ct. App., Wash., 2002)

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