## Facts

- The Society of Lloyd’s administers a London insurance market in which individual investors (“Names”) underwrite insurance through syndicates and bear the associated risks.
- To become Names, Gillian and Uwe Siemon-Netto signed a standard General Undertaking that authorized Lloyd’s governing council to enter later agreements on their behalf.
- In response to large long-tail liabilities, Lloyd’s adopted a market-wide reconstruction and reinsurance plan, including required premium payments connected to a reinsurance vehicle (Equitas).
- Acting under the authorization clause in the General Undertaking, Lloyd’s council executed the reconstruction plan on behalf of the Names, including the Siemon-Nettos.
- The Siemon-Nettos refused to pay the required reinsurance premiums.
- Lloyd’s sued in the English High Court (Queen’s Bench Division) for breach of contract and obtained money judgments for the unpaid amounts.
- Lloyd’s filed suit in the U.S. District Court for the District of Columbia to recognize and enforce the English judgments under the District’s Uniform Foreign Money Judgments Recognition Act (UFMJRA).
- The district court struck the Siemon-Nettos’ affirmative defenses and granted summary judgment recognizing and enforcing the English judgments.

## Issues

1. Whether the English money judgments were recognizable and enforceable in the District of Columbia under the UFMJRA.
2. Whether recognition should be denied under the UFMJRA’s public-policy exception because (a) the Siemon-Nettos did not personally sign the reconstruction plan, (b) Lloyd’s bylaws or the plan allegedly violated English law, or (c) Parliament allegedly made an improper delegation of regulatory authority to Lloyd’s.

## Decision

- The D.C. Circuit affirmed the summary judgment enforcing the English money judgments.
- The court held that none of the asserted objections satisfied the UFMJRA’s public-policy exception.
- The court concluded that the judgments were not repugnant to District of Columbia (or U.S.) public policy and were entitled to recognition.

## Legal Principles

- Under the UFMJRA, recognition of a final foreign money judgment is the general rule; refusal based on public policy is a narrow exception.
- “Repugnance” for public-policy nonrecognition requires a clear conflict with fundamental notions of justice or morality; mere differences between foreign and domestic law or institutions are insufficient.
- When a debtor authorized an entity by contract (here, via a General Undertaking) to enter later agreements on the debtor’s behalf, obligations arising from actions within that authorization do not, without more, offend public policy.
- In recognition proceedings, U.S. courts generally do not re-litigate a foreign court’s interpretation of its own law; final foreign judgments are not treated as subject to appellate-style review in the enforcing forum absent a qualifying statutory ground for nonrecognition.
- A foreign legislature’s choice to grant regulatory authority to a private organization does not, by itself, make resulting foreign judgments unrecognizable under the UFMJRA if the issuing court was competent and the proceedings were fundamentally fair.

## Conclusion

The D.C. Circuit enforced English money judgments obtained by Lloyd’s against U.S. investors who refused to pay premiums required by a market-wide reinsurance plan, holding that the UFMJRA’s public-policy exception did not apply and that objections based on lack of direct signature, asserted illegality under English law, and alleged legislative delegation were insufficient to defeat recognition.


Society of Lloyd's v. Siemon-Netto, 457 F.3d 94 (D.C. Cir. 2006)