Hilton vs.

Guyot(1895)
FACTS:
1. Guyot, a Frenchman, sued Hilton, an American, in a French court for the recovery of asum of money. The French court
rendered judgment in favor of Guyot.
2. Plaintiff brought the action to a US court to recover the sum of money adjudged by the French court to be due from
the defendant to the plaintiff.

ISSUE: Whether or not a judgment of a foreign nation’s court entitled to full credit and has a conclusive effect when sued
to other nation.

HELD:
1. No law has any effect, of its own force, beyond the limits of the sovereignty from which its authority is derived. The
extent to which the law of one nation, as put in force within its territory, whether by executive order, by legislative act, or
by judicial decree shall be allowed to operate within the dominion of another nation depends upon the comity of
nations.
2. A foreign judgment is not entitled to full faith and credit when sued upon another nation, but is a prima facie evidence
only of the claim.

Hilton v. Guyot

CASE SYNOPSIS
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.

CASE FACTS
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.

DISCUSSION
 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.

CONCLUSION
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.