Hilton vs Guyot

FACTS: Guyot, a Frenchman, sued Hilton, an American, in a French court for the
recovery of a sum of money. The French court rendered judgment in favor of Guyot.
Plaintiff brought the action to a US court to recover the sum of money adjudged by the
French court to be due from the defendant to the plaintiff.
ISSUE: Whether or not a judgment of a foreign nation’s court entitled to full credit
and has a conclusive effect when sued to other nation.
HELD:
No law has any effect, of its own force, beyond the limits of the sovereignty from which
its authority is derived. The extent to which the law of one nation, as put in force within
its territory, whether by executive order, by legislative act, or by judicial decree, shall be
allowed to operate within the dominion of another nation, depends upon what our
greatest jurists have been content to call 'the comity of nations.' Although the phrase
has been often criticized no satisfactory substitute has been suggested.
‘Comity,’ in the legal sense, is neither a matter of absolute obligation, on the one hand,
nor of mere courtesy and good will, upon the other. But it is the recognition which one
nation allows within its territory to the legislative, executive or judicial acts of another
nation, having due regard both to international duty and convenience, and to the rights
of its own citizens, or of other persons who are under the protection of its laws.
Now, the rule is universal in this country that private rights acquired under the laws of
foreign states will be respected and enforced in our courts unless contrary to the policy
or prejudicial to the interests of the state where this is sought to be done; and, although
the source of this rule may have been the comity characterizing the intercourse between
nations, it prevails to-day by its own strength, and the right to the application of the law
to which the particular transaction is subject is a juridical right