## Facts

- John P. Granger worked for Ingersoll Milling Machine Co. in Illinois, then transferred by agreement in 1971 to Brussels to work for Ingersoll’s Belgian subsidiary.
- Granger negotiated transfer terms addressing compensation, benefits, and expenses related to the move to Belgium.
- Granger later became manager of the Belgian subsidiary, was placed on its payroll, and was treated as employed in Belgium for tax purposes.
- His employment ended effective December 31, 1977.
- In 1978, Granger sued Ingersoll and the Belgian subsidiary in a Brussels labor court for termination compensation and related benefits under Belgian law.
- In the Belgian litigation, both defendants appeared and litigated; each argued the other entity was Granger’s sole employer, and Ingersoll asserted a counterclaim seeking reimbursement of certain expenses.
- Belgian courts found Granger had been employed by both entities, awarded him termination-related amounts, and granted Ingersoll partial relief on its counterclaim; the judgment became final after review by Belgium’s court of last resort.
- While the Belgian case was pending, Ingersoll filed a U.S. action seeking declaratory relief denying Granger’s entitlement to benefits and seeking the same expense reimbursement; Granger counterclaimed to enforce any final Belgian judgment.
- After finality in Belgium, the federal district court entered judgment enforcing the Belgian money judgment for Granger and against Ingersoll.

## Issues

1. Whether the Belgian courts’ final money judgment against Ingersoll should be recognized and enforced in the United States.
2. Whether recognition should be denied due to asserted lack of personal or subject-matter jurisdiction in Belgium.
3. Whether Belgian procedures were incompatible with U.S. due process such that recognition must be refused.
4. Whether enforcement would violate U.S. public policy because the judgment applied Belgian employment law and produced a result unfavorable to Ingersoll.
5. Whether the parallel U.S. action or the district court’s case-management decisions warranted refusing recognition of the Belgian judgment.

## Decision

- The Seventh Circuit affirmed the district court’s judgment enforcing the Belgian money judgment.
- The court held Belgium had jurisdiction over the dispute and over Ingersoll, particularly given the Belgian locus of employment and Ingersoll’s participation in the Belgian case.
- The court found the Belgian proceedings provided procedures compatible with due process, noting Ingersoll’s active litigation and lack of a persuasive showing of unfairness.
- The court rejected the public-policy challenge, concluding that application of different substantive law or a more employee-protective regime does not, without more, bar recognition.
- The court rejected arguments based on the existence of the parallel U.S. case, concluding the district court acted consistently with comity and that the final Belgian judgment resolved the duplicated dispute.

## Legal Principles

- Final foreign-country money judgments are generally entitled to recognition and enforcement unless a recognized ground for nonrecognition applies.
- A party’s voluntary appearance and active litigation in the foreign forum strongly supports personal jurisdiction and limits later collateral jurisdictional attacks.
- Due process for recognition purposes requires procedures compatible with fundamental fairness, not procedural identity with U.S. courts.
- Recognition is not barred merely because foreign substantive law differs from U.S. law or yields a result one party dislikes; denial on public-policy grounds requires a fundamental conflict with basic domestic policy.
- A parallel domestic action does not prevent recognition of a later final foreign judgment resolving the same controversy; comity and efficient administration may support allowing the foreign case to proceed to judgment.

## Conclusion

The Seventh Circuit upheld enforcement of a final Belgian employment-related money judgment against Ingersoll because the Belgian courts had proper jurisdiction, the proceedings were fair under due process standards, no fundamental public-policy conflict was shown, and the parallel U.S. case did not justify refusing recognition.


Ingersoll Milling Mach. Co. v. Granger, 833 F.2d 680 (7th Cir. 1987)