Law School Case Brief
Hilton v. Guyot - 159 U.S. 113, 16 S. Ct. 139 (1895)
Comity 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.
Plaintiff Guyot, an administrator of a French firm, sued defendants Libbey and Hilton, who were U.S. citizens doing business in Paris, France, in a French court under a contract claim. Defendants appeared and litigated the merits of the case, alleging fraud on the part of plaintiffs, and sought an injunction from bringing suit, but the court would not admit evidence and entered a directed verdict for plaintiff. The judgment was affirmed in a French appeals court. Plaintiff Guyot sought to enforce the French judgment in the district court of New York, which, without retrial on the merits, directed a verdict for plaintiffs in the amount a French court had awarded. Libbey and Hilton sought review in the United States Supreme Court.
Did the comity of the United States require the court to give conclusive effect to the judgments of the courts of France?
The United States Supreme Court found that comity was reciprocal. Because France did not recognize final judgments of the United States and would try such judgments anew, French judgments would be given the same treatment. Thus, the comity of the United States did not require the court to give conclusive effect to the judgments of the courts of France. Defendants could receive a new trial.
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