(a) Any objection to the recognition and entry of the tribal court money judgment sought under Section 1734 shall be served and filed within 30 days of service of the notice of filing. If any objection is filed within this time period, the superior court shall set a time period for replies and set the matter for a hearing. The hearing shall be held by the superior court within 45 days from the date the objection is filed unless good cause exists for a later hearing. The only grounds for objecting to the recognition or enforcement of a tribal court money judgment are the grounds set forth in subdivisions (b), (c), and (d).
§ 1737.Objections
Title 11. Money Judgments of Other Jurisdictions · Chapter 3. Tribal Court Civil Money Judgment Act · Last amended 2022 · Last verified July 29, 2026
In one sentenceSection 1737 sets a 30-day deadline and prompt hearing schedule for objecting to recognition of a tribal court money judgment, and lists the mandatory, discretionary, and conflicting-judgment grounds a respondent can raise, with the burden shifting to the objecting party once the applicant shows entitlement to recognition.
Full Text of § 1737
(b) A tribal court money judgment shall not be recognized and entered if the respondent demonstrates to the superior court that at least one of the following occurred:
(1) The tribal court did not have personal jurisdiction over the respondent.
(2) The tribal court did not have jurisdiction over the subject matter.
(3) 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.
(1) The superior court shall decline to recognize and enter a tribal court money judgment if any one of the following grounds applies:
(A) The defendant in the proceeding in the tribal 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 or claim for relief on which the judgment is based is repugnant to the public policy of the state or of the United States.
(D) The proceeding in the tribal 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 tribal court.
(E) In the case of jurisdiction based on personal service only, the tribal court was a seriously inconvenient forum for the trial of the action.
(F) The judgment was rendered under circumstances that raise substantial doubt about the integrity of the rendering court with respect to the judgment.
(G) The specific proceeding in the tribal court leading to the judgment was not compatible with the requirements of due process of law.
(H) The judgment includes recovery for a claim of defamation, unless the court determines that the defamation law applied by the tribal court provided at least as much protection for freedom of speech and the press as provided by both the United States and California Constitutions.
(2) Notwithstanding an applicable ground for nonrecognition under paragraph (1), the court may nonetheless recognize a tribal court money judgment if the applicant demonstrates good reason to recognize the judgment that outweighs the ground for nonrecognition.
(d) The superior court may, in its discretion, decline to recognize and enter a tribal court money judgment if the judgment conflicts with another final and conclusive judgment.
(e) If objections have been timely filed, the applicant has the burden of establishing that the tribal court money judgment is entitled to recognition. If the applicant has met its burden, a party resisting recognition of the tribal court money judgment has the burden of establishing that a ground for nonrecognition exists pursuant to subdivision (b), (c), or (d).
Plain-English Summary
Section 1737 is the heart of the recognition fight when a respondent decides to push back. An objection has to be served and filed within 30 days of the notice of filing, and once one lands, the superior court sets a reply schedule and holds a hearing within 45 days unless good cause justifies waiting longer. The section then narrows what a respondent can argue: only the grounds it lists in subdivisions (b), (c), and (d) count.
Three grounds are mandatory, meaning the court has to refuse recognition if the respondent proves them: the tribal court lacked personal jurisdiction, lacked subject-matter jurisdiction, or rendered the judgment under a system without impartial tribunals or due process. A longer list of grounds in subdivision (c), covering things like inadequate notice, fraud that undercut the losing party's chance to defend, conflict with California or federal public policy, a forum-selection agreement the tribal proceeding ignored, a seriously inconvenient forum, doubts about the rendering court's integrity, incompatible due process, or a defamation judgment lacking free-speech protections comparable to state and federal constitutional standards, normally blocks recognition too, but the court can still recognize the judgment despite one of these grounds if the applicant shows a good reason that outweighs it. A separate, purely discretionary ground lets the court decline recognition if the judgment conflicts with another final judgment. Once the applicant establishes the judgment is entitled to recognition, the burden shifts to whoever resists recognition to prove one of these grounds applies.
Frequently Asked Questions
How long does a respondent have to object, and when is the hearing held?
The objection must be served and filed within 30 days of the notice of filing, and the hearing takes place within 45 days of that objection unless good cause supports a later date.
What grounds force a court to refuse recognition?
Lack of personal jurisdiction over the respondent, lack of subject-matter jurisdiction, or a judicial system that didn't provide impartial tribunals or due process.
Can a court recognize a judgment even if one of the listed grounds against it applies?
Yes, for the grounds in subdivision (c): the court may still recognize the judgment if the applicant shows good reason to do so that outweighs the ground for nonrecognition.
Who has the burden of proof once an objection is filed?
The applicant must first establish the judgment is entitled to recognition; if that's shown, the burden shifts to the party resisting recognition to prove a ground for nonrecognition.
Can a court decline recognition just because of a conflicting judgment?
Yes. Subdivision (d) lets the court decline, in its discretion, to recognize a tribal court money judgment that conflicts with another final and conclusive judgment.
Amendment History
Amended by Stats 2021 ch 58 (AB 627),s 6, eff. 1/1/2022. Amended by Stats 2017 ch 168 (AB 905),s 14, eff. 1/1/2018. Added by Stats 2014 ch 243 (SB 406),s 4, eff. 1/1/2015.
Source & verification. Section text is reproduced verbatim from
the Deering's California Codes Annotated / vLex. Enacted by the California Legislature.
Last verified July 29, 2026.
· Official source
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