Mr. Cueto contended that he never made any contract in
Maryland, had not committed a tortious or wrongful act in Maryland, and has not
been physically present in Maryland since 1969. In their oppositions, St. Paul
and ABHI argued that the United States District Court for the District of
Maryland had personal jurisdiction over Mr. Cueto because he enrolled the
Illinois default judgments in Maryland courts. Mr. Cueto argued that his
enrollment of the foreign judgments, absent any attempts to enforce them, was an
insufficient basis for personal jurisdiction.
A federal court may exercise jurisdiction over a
non-resident defendant if: (1) the requirements of the forum state's long-arm
statute are satisfied; and (2) the exercise of jurisdiction comports with the
Due Process Clause of the Fourteenth Amendment. Specifically, Maryland's
long-arm statute provides that personal jurisdiction exists over anybody who
transacts any business or performs any character of work or service in the
State. MD. CODE ANN., CTS. & JUD. PROC. § 6-103(b)(1). The Court of Appeals has
held that acts done within the State, which will support in personam
jurisdiction as transacting "any business," include acts which constitute a
purposeful activity within the State.
The Maryland Courts have not yet addressed the question of
whether the enrollment of foreign judgments constitutes purposeful availment of
state law and satisfies the "[t]ransacts any business" requirement of the
state's long-arm statute. Neither Maryland, nor any other Court has directly
decided the issue under its own long-arm statute or as a matter of
constitutional due process. Likewise, the Uniform Enforcement of Foreign
Judgments Act ("UEFJA") is silent on the issue of whether filing a foreign
judgment confers personal jurisdiction in other proceedings. Therefore, given
the lack of precedent and statutory guidance, the Court treated this issue as
one of first impression.
The United States District Court for the District of
Maryland held that a non-resident defendant who enrolls foreign default
judgments in Maryland pursuant to UEFJA "[t]ransacts . . . . business" within
the meaning of Maryland's long-arm statute. The Court arrived at this conclusion
based on the similarities between the purposeful availment of a state's laws and
protections when a judgment creditor enrolls a foreign default judgment and when
a litigant files a lawsuit. A foreign judgment filed pursuant to UEFJA is
treated as a Maryland judgment for all intents and purposes. Thus, the outcome
of a proceeding under UEFJA is similar to those of a civil action. Just as civil
actions voluntarily initiated by non-residents may constitute purposeful
availment of the laws and protections of Maryland, so also should foreign
judgment enrollment proceedings.
By enrolling the Illinois default judgments against ABHI in
Maryland, the Court found that Mr. Cueto transacted business and engaged in
purposeful activity in Maryland. Therefore, the Maryland long-arm statute
authorized the exercise of personal jurisdiction over him for matters arising
from or relating to the enrollment of the Illinois default judgments in
Maryland. Since St. Paul's declaratory judgment action directly related to the
Illinois default judgments enrolled in Maryland, the Court had personal
jurisdiction over him.
The Court also found that the exercise of jurisdiction over
Mr. Cueto was constitutionally reasonable. First, Mr. Cueto cannot say that
litigating in Maryland is unduly burdensome when he enrolled three foreign
judgments in the Maryland courts. Second, Maryland has great interest in
adjudicating this dispute. Third, St. Paul has a strong interest in resolving
the dispute in Maryland, because it is the only forum in which both Mr. Cueto
and ABHI has sufficient contact. Fourth, the States have an interest in
adjudicating claims in a single action against all defendants. Fifth, Maryland
courts are in the best position to further the social policies implicated by
this action. For these reasons, the "traditional notions of fair play and
substantial justice" are not offended by the exercise of jurisdiction over Mr.
Cueto in the United States District Court for the District of Maryland.