## Facts

- Lloyd’s of London operates an insurance market in which individual investors (“names”) participate in underwriting through syndicates subject to contracts administered by Lloyd’s.
- The names entered agreements containing forum-selection provisions directing disputes to English courts and permitting Lloyd’s to obtain English judgments for amounts Lloyd’s determined were owed.
- Lloyd’s obtained money judgments in the Queen’s Bench Division against the names for several hundred thousand dollars each.
- The English Court of Appeal affirmed, and further review was denied by the House of Lords.
- Lloyd’s sought collection in federal court in Illinois, invoking Illinois’s recognition statute for foreign money judgments and, after recognition, Illinois execution procedures through citation proceedings to identify and reach assets.
- The names did not comply with the citations and instead opposed recognition of the English judgments.

## Issues

1. Whether Illinois’s Uniform Foreign Money-Judgments Recognition Act permits nonrecognition of English money judgments on the ground that the English legal system allegedly lacks “impartial tribunals or procedures compatible with the requirements of due process of law.”
2. Whether the Act’s due-process inquiry focuses on alleged defects in the particular foreign proceedings or on systemic fairness of the foreign judicial system.

## Decision

- The Seventh Circuit affirmed summary judgment enforcing the English judgments.
- The court held that the English judicial system provides impartial tribunals and procedures compatible with due process for purposes of the Illinois recognition statute.
- The court rejected the attempt to treat U.S. courts as an additional appellate layer over the English litigation.
- Having recognized the judgments, the court approved use of Illinois citation proceedings under Federal Rule of Civil Procedure 69(a) to execute on the domesticated judgments.

## Legal Principles

- Under Illinois’s Uniform Foreign Money-Judgments Recognition Act, the “due process” ground for nonrecognition addresses whether the foreign *system* of justice lacks impartial tribunals or fundamentally fair procedures, not whether the foreign court committed case-specific error.
- Courts generally will recognize money judgments from established judicial systems that provide fair and neutral forums, including England’s courts, absent proof of systemic unfairness.
- Recognition proceedings are not de novo review of the foreign merits; the recognition inquiry is limited to threshold statutory criteria rather than relitigation of the underlying dispute.
- In federal court, post-judgment enforcement follows state execution procedure under Rule 69(a); in Illinois, citation proceedings may be used to discover assets, impose liens, and compel turnover to satisfy a judgment.

## Conclusion

The Seventh Circuit enforced Lloyd’s English money judgments in Illinois, holding that the English court system satisfies the recognition statute’s systemic due process requirement and permitting collection through Illinois citation-based execution procedures once the judgments were recognized.


Soc’y of Lloyd’s v. Ashenden, 233 F.3d 473 (7th Cir. 2000)