## Facts

- DocRx, Inc. and EMI Services of North Carolina, LLC entered a contract requiring EMI to pay DocRx a 25% commission on net profits from certain pharmaceutical sales.
- DocRx sued EMI in an Alabama state court for breach of contract after alleging nonpayment.
- EMI did not appear, and the Alabama court entered a default judgment based on an affidavit from DocRx’s CEO describing sales volume and profitability used to calculate damages.
- DocRx filed the authenticated Alabama money judgment in North Carolina for enforcement under the Uniform Enforcement of Foreign Judgments Act (UEFJA).
- EMI moved in North Carolina for relief from enforcement under Rule 60(b)(3), asserting the affidavit contained false statements and that the judgment was procured by fraud.

## Issues

1. Whether the Full Faith and Credit Clause permits a North Carolina court to refuse enforcement of a sister-state money judgment based on alleged intrinsic fraud (false evidence used in the rendering court).
2. Whether, and to what extent, North Carolina Rule 60(b)(3) provides a defense to enforcement of a foreign judgment filed under the UEFJA.

## Decision

- The Supreme Court of North Carolina modified and affirmed the Court of Appeals, which had vacated the trial court’s order and remanded.
- North Carolina courts must enforce a final, valid sister-state money judgment when the rendering court had jurisdiction and due process was satisfied.
- Allegations that damages were supported by false testimony or affidavits are intrinsic fraud and do not justify denying enforcement in North Carolina.
- Rule 60(b)(3) cannot be used to collaterally relitigate the merits or correctness of the rendering court’s damages determination; any such challenge must be pursued in the rendering state.

## Legal Principles

- A sister-state judgment that is final, valid, and entered with personal and subject-matter jurisdiction is entitled to full faith and credit in North Carolina.
- Under the UEFJA, a filed foreign judgment is enforceable like a North Carolina judgment, but defenses are limited by full faith and credit.
- Collateral attack on a foreign judgment in North Carolina is generally limited to jurisdictional defects or due-process violations.
- Intrinsic fraud (fraud occurring within the proceedings, such as false evidence) is not a permissible basis in North Carolina to refuse enforcement of a sister-state judgment; remedies for intrinsic fraud lie in the rendering state.
- Rule 60(b) relief in foreign-judgment enforcement proceedings is available only to the extent consistent with full faith and credit.

## Conclusion

The court held that North Carolina must enforce the Alabama default money judgment because EMI’s challenge alleged only intrinsic fraud in the proof of damages, which cannot defeat full faith and credit; any remedy for that alleged fraud must be sought in Alabama.


DocRx, Inc. v. EMI Servs. of N.C., LLC, 367 N.C. 371 (2014)