In 2022, the Appellate Division of the New York State Supreme Court unanimously reversed the trial court ruling, rejecting the blanket non-recognition of Chinese judgments (Shanghai Yongrun Inv. Mgmt. Co. v. Xu, et al., 203 A.D.3d 495, 160 N.Y.S.3d 874 (N.Y. App. Div. 2022)).
US-China Judgments Recognition and Enforcement
It is more than likely that a Chinese judgment would be enforced in a UFMJRA state, given that 30 out of 50 states in the U.S. have adopted the 2005 revision of the UFMJRA, including every major jurisdiction like New York, California, and Texas.
Can I sue Chinese companies in the United States and then enforce a US judgment in China?
In 2021, the Superior Court of Washington for King County ruled to recognize a judgment of a Beijing local court, marking the first time for a Washington state court, and the sixth time for a US court, to recognize and enforce Chinese monetary judgments (Yun Zhang v. Rainbow USA Investments LLC, Zhiwen Yang et al., Case No. 20-2-14429-1 SEA).
In 2022, Guangzhou Intermediate People’s Court of China ruled to partially recognize and enforce three EB-5 visa fraud-related judgments rendered respectively by the US District Court for the Central District of California and the Superior Court of California, County of Los Angeles.
In 2020, Ningbo Intermediate People’s Court of China ruled in Wen v. Huang et al. (2018) to recognize and enforce a US judgment, marking the third time that American monetary judgments have been enforced in China.
Finality matters. In 2020, Wuxi Intermediate People's Court of China dismissed an application for enforcing a US judgment, due to the lack of finality, in Wuxi Luoshe Printing & Dyeing Co. Ltd. v. Anshan Li et al. (2017).
The Case of Huizhi Liu is the third Chinese judgment recognized in the U.S. and the first in New York.
Chinese courts recognized and enforced a U.S. judgment for the second time, indicating that U.S. judgments have begun to be recognized and enforced in China in a normalized way. Any U.S. judgment, whether made by a federal court or a state court, may be recognized and enforced in China.
Judge Zhao Qianxi, who rendered the first ruling to recognize and enforce a US court judgment in China, talks about his process of reflection in hearing the case.