I've never thought about it before -- and I've taught Civil Procedure for over a quarter century -- but, yeah, I agree with the Court of Appeal that a judgment debtor doesn't have to have minimum contacts with the state in which a sister state judgment is rendered. If Nevada enters a judgment against me, and I had the requisite minimum contacts with Nevada (the forum state), then the plaintiff can subsequently register that judgment in California even if I have zero contacts with California. The minimum contacts analysis only applies to the rendering court, not the subsequent forum in which the judgment is registered. Because the registration doesn't create a new judgment; it's only enforcing the old one. (Plus, if you have no contacts with the subsequent state anyway, then you won't care much that there's a judgment against you in the state in which you have zero contacts, right?)
So Justice Krause's opinion seems entirely right to me.
Nonetheless, doesn't it strike you as strange that the plaintiff can accomplish what it successfully did here? The judgment in Nevada expired after 6 years, and wasn't renewed. So that's the end of the judgment in Nevada, right? In the interim, however, the Nevada judgment was registered in California, and thereafter renewed for another 10 years. That seems fine; there's a California judgment at that point, but not a Nevada judgment (since it expired). That's the way these things work.
But then plaintiff uses the existing California judgment and registers it in Nevada. Which Nevada apparently allows.
That just strikes me as strange. If Nevada wants judgments to expire after six years (if they're not renewed during the relevant Nevada time frame), why would Nevada allow a plaintiff to circumvent this rule by registering the judgment elsewhere and then "bouncing it back" long after the expiration of the underlying Nevada judgment?
I get that Nevada gets to do whatever Nevada feels like doing, and that that's not an issue for a court in California.
But seems like a bad rule to me.
