Midbrook Flowerbulbs Holland v. Holland America Bulb Farms
United States Court of Appeals for the Ninth Circuit
874 F.3d 604 (2017)
- Written by Rich Walter, JD
Facts
Midbrook Flowerbulbs Holland B.V. (Midbrook) (plaintiff), a Dutch company, sued Holland America Bulb Farms, Inc. (Holland America) (defendant), an American company, over a billing dispute. The Dutch trial court denied Holland America’s motion for broad pretrial discovery but permitted limited discovery. Although the trial court rendered one fact-finding in Holland America’s favor, the trial court ultimately entered judgment for Midbrook and awarded damages. On appeal, a Dutch appellate court overturned the trial court’s factual finding but reopened and broadened the scope of discovery. The resulting disclosures persuaded the appellate court to reduce the amount of Midbrook’s damages award. At each step in the Dutch proceedings, the trial and appellate courts fully explained their decisions and responded to each of Holland America’s objections. Invoking the Uniform Foreign Money Judgments Recognition Act (UFMJRA), Midbrook sued to enforce the Dutch judgment in the United States. The federal district court granted summary judgment for Midbrook. Holland America appealed to the Ninth Circuit, arguing that the trial court’s limit on pretrial discovery and the appellate court’s reversal of the trial court’s factual finding deprived Holland America of due process.
Rule of Law
Issue
Holding and Reasoning (Bea, J.)
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