## Facts

- John Paul DeJoria and associates formed a Moroccan oil-exploration company to pursue drilling opportunities in Morocco, relying on foreign and local participants.
- A Liechtenstein-based investor invested substantial funds, later alleging it was induced by misrepresentations about prior investment levels and the oil prospects.
- The project received prominent public attention in Morocco, including statements forecasting major oil discoveries, but results did not meet expectations.
- The investor and the company (as successors/related entities) sued DeJoria and others in Moroccan courts for fraudulent inducement and related claims.
- A Moroccan court entered a money judgment of roughly $122–$123 million against DeJoria and others; DeJoria was later severed from co-defendants and tried separately.
- DeJoria asserted he did not return to Morocco after 2000 due to safety concerns and contended this impaired his ability to participate in his defense.
- The judgment creditors sought recognition and enforcement in Texas under the Texas Recognition of Foreign Country Money Judgments Act.
- DeJoria sued in federal court for a declaration that the Moroccan judgment should not be recognized or enforced under the Act.

## Issues

1. Whether Morocco’s judicial system lacked impartial tribunals or procedures compatible with due process, requiring non-recognition under the Texas Recognition Act.
2. Whether the Moroccan proceedings against DeJoria, in particular, denied due process through unfair procedures or political influence.
3. Whether discretionary non-recognition grounds applied, including fundamental unfairness or fraud in obtaining the judgment.

## Decision

- The court denied recognition and enforcement of the Moroccan judgment in Texas.
- The court found DeJoria met his burden to show Morocco’s judicial system did not provide impartial tribunals or due-process-compatible procedures, triggering mandatory non-recognition.
- The court also found the specific Moroccan proceedings were inconsistent with basic procedural fairness, providing additional support for non-recognition.
- Judgment was entered declaring the Moroccan judgment unenforceable in Texas.

## Legal Principles

- Under the Texas Recognition of Foreign Country Money Judgments Act, foreign-country money judgments are generally recognizable unless a statutory ground for non-recognition is proven.
- Recognition must be denied if the foreign country’s judicial system does not provide impartial tribunals or procedures compatible with due process.
- The due process inquiry does not require procedures identical to those in U.S. courts, but does require basic fairness and a meaningful opportunity to be heard.
- Courts may also deny recognition on discretionary grounds when the particular proceedings are fundamentally unfair or otherwise offend the Act’s standards.

## Conclusion

The court refused to recognize and enforce the Moroccan money judgment because the record showed a system-wide deficiency in impartiality and due-process-compatible procedures in Morocco’s courts and, independently, that the proceedings against DeJoria did not provide adequate procedural fairness under the Texas Recognition Act.


DeJoria v. Maghreb Petrol. Expl. S.A., 38 F. Supp. 3d 805 (W.D. Tex. 2014)