## Facts

- Silbrico Corporation obtained a Wisconsin settlement resolving litigation over a roofing project at a Wisconsin shopping center.
- Under a Wisconsin-filed stipulation, Raanan was to pay $12,500; upon default, after written notice and a seven-day cure period, judgment could be entered for $16,000.
- After Raanan failed to pay, a Wisconsin court entered a $16,000 judgment on March 3, 1983, based on counsel’s affidavit stating notice of default was given and no payment was made.
- Silbrico filed the Wisconsin judgment in Los Angeles Superior Court under the Sister State and Foreign Money Judgments Act, and a California judgment was entered on July 28, 1983.
- Raanan moved to vacate, asserting due process defects and lack of required notice; the motion was taken off calendar.
- Silbrico then had the first Wisconsin judgment vacated, reissued notice to address the notice dispute, and obtained a second Wisconsin judgment for $16,000 on February 20, 1984.
- The California court vacated the earlier California judgment and entered a new California judgment on the second Wisconsin judgment; Raanan appealed.

## Issues

1. Whether the second Wisconsin money judgment was entitled to full faith and credit and enforceable in California under the Sister State and Foreign Money Judgments Act.
2. Whether California could refuse enforcement because the Wisconsin stipulated judgment allegedly functioned as a “judgment by confession” that would not satisfy California statutory formalities.
3. Whether California could refuse enforcement because the $16,000 default judgment amount (versus a $12,500 payment obligation) was an unenforceable penalty or improper liquidated damages under California law.

## Decision

- The Court of Appeal affirmed the California judgment enforcing the second Wisconsin judgment.
- The Wisconsin court had jurisdiction over the parties and subject matter, and the second Wisconsin proceeding provided reasonable notice and an opportunity to be heard.
- Raanan’s “judgment by confession” and penalty/liquidated-damages arguments were not valid defenses to enforcement under the Act because they attacked the merits and substantive policy, not jurisdiction or comparable fundamental defects.

## Legal Principles

- A sister-state judgment must be recognized in California if the rendering state had jurisdiction over the parties and subject matter and afforded reasonable notice and an opportunity to be heard.
- The Sister State and Foreign Money Judgments Act provides an expeditious enforcement procedure and permits only limited defenses (e.g., lack of jurisdiction, extrinsic fraud, satisfaction, or similarly fundamental defects).
- California may not deny full faith and credit by applying California procedural statutes (such as confession-of-judgment requirements) to invalidate a properly rendered sister-state judgment.
- Disagreement with the sister state’s enforcement of a stipulated default-judgment mechanism, or with the amount as a purported penalty under California law, is not a basis to refuse enforcement absent a recognized, exceptional ground.

## Conclusion

California was required to enforce the second Wisconsin $16,000 judgment because Wisconsin had jurisdiction and the proceedings satisfied due process; challenges based on California’s confession-of-judgment rules or penalty doctrine were impermissible collateral attacks under the Sister State and Foreign Money Judgments Act.


Silbrico Corp. v. Raanan, 170 Cal. App. 3d 202, 216 Cal. Rptr. 201 (Ct. App. 1985)