## Facts

- Carol Conglis sued Richard Radcliffe in Tennessee state court on a promissory note after Radcliffe allegedly defaulted.
- Radcliffe was personally served in the Tennessee action and received notice of the Tennessee trial date but did not appear.
- The Tennessee court entered a default judgment in Conglis’s favor.
- Conglis later filed the Tennessee judgment in New Mexico, where Radcliffe was living, under New Mexico’s foreign-judgment act and sought to execute on Radcliffe’s property.
- Radcliffe moved in New Mexico to set aside (or obtain relief from) the filed Tennessee judgment, arguing that the foreign-judgment act required New Mexico to treat the Tennessee judgment as if it were a New Mexico judgment and therefore permitted relief based on fraud and other reasons.
- The New Mexico trial court denied Radcliffe’s request for relief from the Tennessee judgment.
- Radcliffe appealed.

## Issues

1. Whether New Mexico’s foreign-judgment act authorizes New Mexico courts to grant relief from a sister-state judgment on the same grounds available to set aside a New Mexico judgment, even when those grounds would exceed the limited collateral attacks allowed under the Full Faith and Credit Clause.
2. Whether Radcliffe’s allegations of fraud and other asserted defects were sufficient to justify setting aside, or otherwise refusing enforcement of, the Tennessee default judgment filed in New Mexico.

## Decision

- The court affirmed the denial of Radcliffe’s motion for relief from the Tennessee judgment.
- New Mexico’s foreign-judgment act was treated as a procedural mechanism for registering and enforcing sister-state judgments; it does not expand the grounds on which a New Mexico court may refuse enforcement of a final judgment from another state.
- The Full Faith and Credit Clause requires New Mexico to enforce a valid, final sister-state judgment, subject only to narrow, traditional defenses (such as lack of jurisdiction in the rendering court or comparable defects affecting the integrity of the proceeding).
- Although New Mexico’s rule allowing relief from judgments (Rule 1-060(B)) may supply the procedure for seeking relief, it cannot be applied to permit a broader merits-based challenge to a sister-state judgment than full faith and credit allows.
- Radcliffe did not show a valid basis to deny full faith and credit to the Tennessee judgment, and his fraud-based assertions were not supported in a way that warranted setting aside the judgment.

## Legal Principles

- Final judgments from sister states must be recognized and enforced under full faith and credit unless a limited, recognized ground for collateral attack is established.
- A state’s foreign-judgment act generally provides an efficient process to file and enforce a sister-state judgment; it does not change the constitutional limits on when enforcement may be refused.
- A forum court may examine whether the rendering court had personal and subject-matter jurisdiction and whether a defect such as extrinsic fraud or a due-process failure justifies denying enforcement.
- Relief-from-judgment procedures cannot be used to relitigate the merits of a sister-state judgment once jurisdiction and basic fairness requirements were satisfied.

## Conclusion

Because the Tennessee default judgment was entered by a court that had jurisdiction over Radcliffe and New Mexico’s foreign-judgment act does not permit broader challenges than full faith and credit allows, the New Mexico court properly refused to set aside the filed Tennessee judgment based on Radcliffe’s asserted fraud and related claims.


Conglis v. Radcliffe, 889 P.2d 1209 (1995)