Case Update (5 March 2026): Chu v. Nanna; Uniform Acts and Foreign Judgment Registration
The parties herein were married in Japan in 2011 with three children born between them. In November 2020, they separated and filed for divorce. On December 16, 2021, a “Conciliation Record (Successful Conciliation)” was entered in the Japanese Court. In this case, the Appellate Court of Illinois, understood this to equate to a court order/judgment. The terms in this “judgment” included spousal support, child support, attorney fees, and a lump sum monetary award to be paid by the Husband to the Wife. It also addressed custody and visitation.
On May 29, 2025, the Wife petitioned a trial court in Illinois to register the foreign “judgment.” She attached an authenticated copy of the “judgment” and alleged that the Husband relocated to Illinois for his employment. She stated that he maintains a bank account at an Illinois bank, and she sought to enforce this judgment against the Husband for lack of payment in Illinois. On July 22, 2025, the Husband’s lawyer entered a special/limited appearance to contest personal jurisdiction over the Husband. On August 6, 2025, he then filed a motion to dismiss the petition to register the Japanese “judgment.” In addition to the lack of personal jurisdiction, he argued that registration was barred by res judicata (the Wife previously attempted to register the “judgment” in Missouri), and that the Foreign Judgments Act, which the Wife sought to use to register the “judgment” does not extend to foreign judgments (only sister-state judgments). The Illinois trial court, in an oral ruling, opined that the Japanese “judgment” could be registered. Husband filed a notice of appeal.
On appeal, the Appellate Court of Illinois referenced two uniform acts. The first is the Uniform Foreign Judgments Act, as it is enacted in Illinois. But, the court said this does not apply here - it only governs enforcement of sister-state judgments. The second is the Uniform Foreign-Country Money Judgments Recognition Act. This act does apply to recognition of certain foreign judgments, but, alas, not to family law judgments. This is an age-old problem. Family law “judgments” (assuming a conciliation record is, in fact, a judgment) are typically addressed different than other civil judgments, and there are different laws that typically apply. No where in this court opinion did the court reference a third uniform act - the Uniform Interstate Family Support Act. While this uniform act may not work to recognize the lump sum agreed to in the Japanese conciliation process (depending on what that lump sum constitutes), it may have some impact on the support matters. Illinois enacted the most recent version of UIFSA in 2015. In fact, read this blog’s post from May 2025, regarding a different Japanese child support order’s recognition in Minnesota.
The end result is that the current request to register the foreign “judgment” is dismissed.
