Sentinel Acceptance Ltd., L.P. v. Hodson Auto Sales & Leasing, Inc.

Janet Hodson (defendant), a Missouri resident, was the president of Hodson Auto Sales & Leasing, Inc. (Hodson Auto) (defendant). Hodson's husband managed the day-to-day affairs of the company while she worked offsite. Sentinel Acceptance, Ltd. (Sentinel) (plaintiff) instituted arbitration proceedings against Hodson and Hodson Auto in California and secured an arbitral award of $16,052.11. Sentinel then filed the award with a California superior court, which entered a judgment confirming the arbitration award. Next, Sentinel registered the California judgment with a Missouri circuit court, seeking garnishment against Hodson and Hodson Auto to satisfy the judgment. Hodson claimed she was not personally served with any information about the arbitration and knew nothing about it. According to Hodson, her husband retained California counsel for her, who put in an appearance and responded to Sentinel's confirmation proceedings on her behalf, all without her knowledge. Hodson's California counsel confirmed that he had no contact with Hodson, only her husband. Hodson moved the Missouri circuit court to quash the registration of the California judgment on the basis of surprise, because she had no knowledge of the California proceedings against her. The trial judge quashed the registration, based on a Missouri rule providing that a foreign judgment registered in the state "is subject to the same procedures, defenses, and proceedings for reopening, vacating, or staying as a judgment of a circuit court" in Missouri. Sentinel appealed.