Revised Code of Washington

Wash. Rev. Code § 6.40A.030 (2026)

✓ current as of May 2026
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(1) Except as otherwise provided in subsections (2) and (3) of this section, a court of this state shall recognize a foreign-country judgment to which this chapter applies.
(2) A court of this state may not recognize a foreign-country judgment if:
(a) The judgment was rendered under a judicial system that does not provide impartial tribunals or procedures compatible with the requirements of due process of law;
(b) The foreign court did not have personal jurisdiction over the defendant; or
(c) The foreign court did not have jurisdiction over the subject matter.
(3) A court of this state need not recognize a foreign-country judgment if:
(a) The defendant in the proceeding in the foreign court did not receive notice of the proceeding in sufficient time to enable the defendant to defend;
(b) The judgment was obtained by fraud that deprived the losing party of an adequate opportunity to present its case;
(c) The judgment or the cause of action on which the judgment is based is repugnant to the public policy of this state or of the United States;
(d) The judgment conflicts with another final and conclusive judgment;
(e) The proceeding in the foreign court was contrary to an agreement between the parties under which the dispute in question was to be determined otherwise than by proceedings in that foreign court;
(f) In the case of jurisdiction based only on personal service, the foreign court was a seriously inconvenient forum for the trial of the action;
(g) The judgment was rendered in circumstances that raise substantial doubt about the integrity of the rendering court with respect to the judgment; or
(h) The specific proceeding in the foreign court leading to the judgment was not compatible with the requirements of due process of law.
(4) A party resisting recognition of a foreign-country judgment has the burden of establishing that a ground for nonrecognition stated in subsection (2) or (3) of this section exists.
[ 2009 c 363 s 4.]
Notes of Decisions
Cited in 4 cases (2 in the last 5 years), 2014–2026 · leading case: Shanghai Com. Bank Ltd. v. Kung Da Chang, 381 P.3d 212 (Wash. Ct. App. 2016).
Shanghai Com. Bank Ltd. v. Kung Da Chang, 381 P.3d 212 (Wash. Ct. App. 2016). “15 RCW 6.40A.030(1), ,020(l)(b). 16 Shanghai Commercial Bank, slip op.”
Alterna Aircraft V B Ltd. v. SpiceJet Ltd. (Wash. 2026). · cites it 6× “RCW 6.40A.030, .040. A judge’s decision on a CR 12(b)(2) motion also requires discretion and judgment.”
Alterna Aircraft V.b. Ltd., V. Spicejet Ltd., 559 P.3d 1026 (Wash. Ct. App. 2024). · cites it 8× “RCW 6.40A.030. When, as here, an appeal concerns the interpretation of a statute, we review the trial court’s decision de novo.”
Shanghai Com. Bank, Resp v. Kung Da Chang & Jane Doe Chang, Apps (Wash. Ct. App. 2014). · cites it 9× “70526-1-1/5 tribunal-specific due process concern grants Washington courts discretion to deny recognition if "[t]he specific proceeding in the foreign court leading to the judgment was not compatible with the requirements of due process of law.”
— Wash. Rev. Code § 6.40A.030(1) — 3 cases
Shanghai Com. Bank Ltd. v. Kung Da Chang, 381 P.3d 212 (Wash. Ct. App. 2016). “15 RCW 6.40A.030(1), ,020(l)(b). 16 Shanghai Commercial Bank, slip op.”
Alterna Aircraft V B Ltd. v. SpiceJet Ltd. (Wash. 2026). “RCW 6.40A.030, .040. A judge’s decision on a CR 12(b)(2) motion also requires discretion and judgment.”
Alterna Aircraft V.b. Ltd., V. Spicejet Ltd., 559 P.3d 1026 (Wash. Ct. App. 2024). “RCW 6.40A.030. When, as here, an appeal concerns the interpretation of a statute, we review the trial court’s decision de novo.”
— Wash. Rev. Code § 6.40A.030(2) — 1 case
Alterna Aircraft V.b. Ltd., V. Spicejet Ltd., 559 P.3d 1026 (Wash. Ct. App. 2024). “RCW 6.40A.030. When, as here, an appeal concerns the interpretation of a statute, we review the trial court’s decision de novo.”
— Wash. Rev. Code § 6.40A.030(2)(a) — 1 case
Shanghai Com. Bank, Resp v. Kung Da Chang & Jane Doe Chang, Apps (Wash. Ct. App. 2014). “70526-1-1/5 tribunal-specific due process concern grants Washington courts discretion to deny recognition if "[t]he specific proceeding in the foreign court leading to the judgment was not compatible with the requirements of due process of law.”
— Wash. Rev. Code § 6.40A.030(2)(b) — 1 case
Alterna Aircraft V B Ltd. v. SpiceJet Ltd. (Wash. 2026). “RCW 6.40A.030, .040. A judge’s decision on a CR 12(b)(2) motion also requires discretion and judgment.”
— Wash. Rev. Code § 6.40A.030(3) — 1 case
Alterna Aircraft V.b. Ltd., V. Spicejet Ltd., 559 P.3d 1026 (Wash. Ct. App. 2024). “RCW 6.40A.030. When, as here, an appeal concerns the interpretation of a statute, we review the trial court’s decision de novo.”
— Wash. Rev. Code § 6.40A.030(3)(c) — 1 case
Shanghai Com. Bank, Resp v. Kung Da Chang & Jane Doe Chang, Apps (Wash. Ct. App. 2014). “70526-1-1/5 tribunal-specific due process concern grants Washington courts discretion to deny recognition if "[t]he specific proceeding in the foreign court leading to the judgment was not compatible with the requirements of due process of law.”
— Wash. Rev. Code § 6.40A.030(3)(g) — 1 case
Shanghai Com. Bank, Resp v. Kung Da Chang & Jane Doe Chang, Apps (Wash. Ct. App. 2014). “70526-1-1/5 tribunal-specific due process concern grants Washington courts discretion to deny recognition if "[t]he specific proceeding in the foreign court leading to the judgment was not compatible with the requirements of due process of law.”
— Wash. Rev. Code § 6.40A.030(3)(h) — 2 cases
Shanghai Com. Bank, Resp v. Kung Da Chang & Jane Doe Chang, Apps (Wash. Ct. App. 2014). “70526-1-1/5 tribunal-specific due process concern grants Washington courts discretion to deny recognition if "[t]he specific proceeding in the foreign court leading to the judgment was not compatible with the requirements of due process of law.”
Alterna Aircraft V B Ltd. v. SpiceJet Ltd. (Wash. 2026). “RCW 6.40A.030, .040. A judge’s decision on a CR 12(b)(2) motion also requires discretion and judgment.”
— Wash. Rev. Code § 6.40A.030(4) — 2 cases
Alterna Aircraft V B Ltd. v. SpiceJet Ltd. (Wash. 2026). “RCW 6.40A.030, .040. A judge’s decision on a CR 12(b)(2) motion also requires discretion and judgment.”
Alterna Aircraft V.b. Ltd., V. Spicejet Ltd., 559 P.3d 1026 (Wash. Ct. App. 2024). “RCW 6.40A.030. When, as here, an appeal concerns the interpretation of a statute, we review the trial court’s decision de novo.”
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