Mass. Gen. Laws » Part III Title II Chapter 235
Massachusetts General Laws

Mass. Gen. Laws ch. 235, § 23A (2026)

Recognition and enforcement of money-judgments of foreign states; definitions

✓ current as of July 2026
Find cases: SyfertCases citing this section MAmalegislature.gov (official) JustiaChapter on Justia CornellLII Search CasesGoogle Scholar

Section 23A. Except as hereinafter provided, any foreign judgment that is final and conclusive and enforceable where rendered even though an appeal therefrom is pending or it is subject to appeal shall be conclusive between the parties to the extent that it grants or denies recovery of a sum of money. The foreign judgment shall be enforceable in the same manner as the judgment of a sister state which is entitled to full faith and credit.

A foreign judgment shall not be conclusive if (1) it was rendered under a system which does not provide impartial tribunals or procedures compatible with the requirements of due process of law; (2) the foreign court did not have personal jurisdiction over the defendant; or (3) the foreign court did not have jurisdiction over the subject matter.

A foreign judgment shall not be recognized if (1) the defendant in the proceedings in the foreign court did not receive notice of the proceedings in sufficient time to enable him to defend; (2) the judgment was obtained by fraud; (3) the cause of action on which the judgment is based is repugnant to the public policy of this state; (4) the judgment conflicts with another final and conclusive judgment; (5) the proceedings in the foreign court were contrary to an agreement between the parties under which the dispute in question was to be settled otherwise than by proceedings in that court; (6) in the case of jurisdiction based only on personal service, the foreign court was a seriously inconvenient forum for the trial of the action; or (7) judgments of this state are not recognized in the courts of the foreign state.

A foreign judgment shall not be refused recognition for lack of personal jurisdiction if (1) the defendant was served personally in the foreign state; (2) the defendant voluntarily appeared in the proceedings, other than for the purpose of protecting property seized or threatened with seizure in the proceedings or of contesting the jurisdiction of the court over him; (3) the defendant prior to the commencement of the proceedings had agreed to submit to the jurisdiction of the foreign court with respect to the subject matter involved; (4) the defendant was domiciled in the foreign state when the proceedings were instituted, or, being a body corporate had its principal place of business, was incorporated, or had otherwise acquired corporate status, in the foreign state; (5) the defendant had a business office in the foreign state and the proceedings in the foreign court involved a cause of action arising out of business done by the defendant through that office in the foreign state; or (6) the defendant operated a motor vehicle or airplane in the foreign state and the proceedings involved a cause of action arising out of such operation.

The courts of this state may recognize other bases of jurisdiction.

If the defendant satisfies the court either that an appeal is pending or that he is entitled and intends to appeal from the foreign judgment, the court may stay the proceedings until the appeal has been determined or until the expiration of a period of time sufficient to enable the defendant to prosecute the appeal.

This section shall not prevent the recognition of a foreign judgment in situations not covered by this section and its provisions.

As used in this section (1) ''foreign state'' means any governmental unit other than the United States, or any state, district, commonwealth, territory, insular possession thereof, or the Panama Canal Zone, the Trust Territory of the Pacific Islands, or the Ryukyu Islands; (2) ''foreign judgment'' means any judgment of a foreign state granting or denying recovery of a sum of money, other than a judgment for taxes, a fine or other penalty, or a judgment for support in matrimonial or family matters.

Notes of Decisions
Cited in 32 cases (4 in the last 5 years), 1980–2022 · leading case: Chase Manhattan Bank, N.A. v. Hoffman, 665 F. Supp. 73 (D. Mass. 1987).
Sort: Relevance Newest Treatment
Chase Manhattan Bank, N.A. v. Hoffman, 665 F. Supp. 73 (D. Mass. 1987). · cites it 10× “In its two count complaint, Chase seeks to enforce the judgment under M.G.L. c. 235, § 23A (Count One) and “principles of common law” (Count Two).”
Desjardins Ducharme v. Hunnewell, 585 N.E.2d 321 (Mass. 1992). · cites it 5× “Hunnewell makes three arguments on appeal: the Superior Court judge erred (1) in concluding that the costs that the Canadian courts assessed against him were enforceable foreign judgments within the meaning of G. L. c. 235, § 23A (1990 ed.), (2) in determining that a Quebec…”
Manches & Co. v. Gilbey, 646 N.E.2d 86 (Mass. 1995). · cites it 4× “On November 9, 1992, Manches commenced this action in the Superior Court in Barnstable County to enforce the foreign judgment pursuant to G. L. c. 235, § 23A (1992 ed.), the Uniform Foreign Money-Judgments Recognition Act.”
C.F. Trust, Inc. v. Peterson, 6 Mass. L. Rptr. 505 (Mass. Super. Ct. 1997). · cites it 7× “Defendants Barrie and Nancy Peterson (collectively “Petersons") oppose the motion on the grounds that under G.L.c. 235, §23A (1986 ed.) the judgment is unenforceable, that C.”
The Soc'y of Lloyd's v. Hamilton, 501 F. Supp. 2d 248 (D. Mass. 2007). · cites it 3× “1 Lloyd’s seeks to recover the *250 amount of the English judgment pursuant to the Massachusetts Uniform Foreign Money-Judgment Recognition Act, Mass. Gen. Laws ch. 235, § 23A () (the “Recognition Act”).”
Comm'r of Taxation & Fin. v. Pelletier, 16 Mass. L. Rptr. 584 (Mass. Super. Ct. 2002). · cites it 5× “235, §23A (entitled “Recognition and enforcement”) provides in pertinent part that: [e]xcept as hereinafter provided, any foreign judgment that is final and conclusive and enforceable where rendered even though an appeal therefrom is pending or it is subject to appeal shall be…”
Goldhammer v. Dunkin' Donuts, Inc., 59 F. Supp. 2d 248 (D. Mass. 1999). “See Mass.Gen.L. ch. 235, § 23A. See generally McCord v.”
Oats v. Whittaker, 18 Mass. L. Rptr. 637 (Mass. Super. Ct. 2005). · cites it 4× “To enforce the Texas judgment, the Oatses filed this action on July 2, 2004, in the Middlesex Superior Court pursuant to G.L.c. 235, §23A, as a complaint and petition for registration of foreign judgment.”
K & R Robinson Enter. Ltd. v. Asian Exp. Material Supply Co., 178 F.R.D. 332 (D. Mass. 1998). · cites it 4× “It then commenced the present lawsuit against those same defendants seeking, among other things, to domesticate the default judgments under Mass.Gen.Laws ch. 235, § 23A K & R has now moved for summary judgment to establish, inter alia, the validity and enforceability of those…”
Evans Cabinet Corp. v. Kitchen Int'l, Inc., 584 F. Supp. 2d 410 (D. Mass. 2008). “See Mass. Gen. Laws Ann. ch. 235, § 23A (West 2000).”
Deborah Berg & Another v. Elaine Ciampa & Another., 100 Mass. App. Ct. 569 (Mass. App. Ct. 2021). “See G. L. c. 235, § 23A. In order to provide a speedy and economical Page 571 method to enforce foreign judgments, the act was adopted "to make uniform the law of those states which enact it.”
Holmes-Marc v. Support Mgmt., Inc. (\SMI-FL\")", 31 Mass. L. Rptr. 378 (Mass. Super. Ct. 2013). · cites it 6× “Recognition of Foreign Judgment The Massachusetts statute governing recognition of foreign judgments is G.L.c. 235, §23A. In relevant part, it provides that “any foreign judgment,” defined to include a judgment issued by another state, “that is final and conclusive and…”
Show all 32 citing cases →
— Mass. Gen. Laws ch. 235, § 23A(6) — 2 cases
Courtesy Car Rental & Sales, Inc. v. Lavelle, 1990 Mass. App. Div. 104 (Mass. Dist. Ct., App. Div. 1990).
Old Vill., Inc. v. Wolf, 1980 Mass. App. Div. 95 (Mass. Dist. Ct., App. Div. 1980).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.