How Courts Treat Foreign Award Judgments: The Unsettled State of US Law and an English Perspective

IBA’s Dispute Resolution International, Vol. 12 No. 2 (2018).

October 2018

The chapter provides guidance to litigants and examines how courts in the United States asked to recognize and enforce a foreign award treat prior foreign judgments from parallel and overlapping proceedings. The article also analyzes how the US position compares with that of the English courts’ approach and discusses how these approaches fit within the broader res judicata and issue estoppel framework.