§ 36A.007.Effect of Recognition of Foreign-Country Judgment

What recognition produces, stated in two parts.

The judgment is conclusive between the parties to the same extent as the judgment of a sister state entitled to full faith and credit in this state would be conclusive.

That is the preclusive effect — the judgment settles what it decided, and the same claim and issues cannot be relitigated between the parties.

Borrowing the sister-state measure is an elegant piece of drafting. Rather than writing a preclusion regime for foreign judgments, the chapter points to a body of law that already exists and is well developed.

The judgment is enforceable in the same manner and to the same extent as a judgment rendered in this state.

So the Texas enforcement machinery becomes available — execution, turnover, garnishment, receivership — once recognition is obtained.

The two-step structure is the difference from the sister-state chapter. There, filing produces enforceability immediately; here, recognition must be established first, and enforceability follows from it.

Both effects are confined by the opening words: "to the extent that the foreign-country judgment grants or denies recovery of a sum of money".

So a judgment doing more than that is recognized only as to the money. Other relief it granted is neither conclusive nor enforceable under this chapter, though it may be recognized under comity by the chapter’s saving clause.

Note that recognition of a judgment denying recovery produces conclusiveness without anything to enforce, which is exactly what a successful foreign defendant needs.