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Domus, Inc. v. Signature Bldg. Sys. of Pa.

Pennsylvania Supreme Court

June 22, 2021

The Pennsylvania Supreme Court considered whether the claim that a foreign judgment was not authenticated under the Uniform Enforcement of Foreign Judgments Act (UEFJA) implicates the subject matter jurisdiction of Pennsylvania’s common pleas courts and therefore cannot be waived. After a court in New Hampshire entered a default judgment against Signature, Domus filed a transfer of judgment in the Court of Common Pleas of Lackawanna Co. The trial court denied Signature’s subsequent motion to strike. Signature appealed, and the Superior Court reversed, ruling Domus’s failure to authenticate the New Hampshire judgment deprived the trial court of subject matter jurisdiction. The Supreme Court reversed and held that the failure to authenticate a foreign judgment under UEFJA does not deprive the common pleas court of subject matter jurisdiction.

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