As anyone who has tried to enforce a judgment against a recalcitrant judgment debtor well knows, obtaining a judgment—no matter how long and hard fought—is often only the beginning of the battle. The confluence of New York’s generous judgment enforcement statutes and the large number of domestic and foreign financial institutions located in New York makes the U.S. District Court for the Southern District of New York a particularly attractive venue for enforcing judgments, even where the judgment is obtained elsewhere.
A recent Southern District decision, JW Oilfield Equip., LLC v. Commerzbank AG,1 illustrates why some have described New York as a “mecca” for judgment creditors and why the Southern District of New York is a favorable forum for registering federal judgments from other districts.2 We discuss that decision below, along with two other recent Southern District decisions highlighting the broad jurisdictional reach of New York’s judgment enforcement provisions, especially when compared with judgments subject to the Foreign Sovereign Immunities Act (FSIA) governing enforcement of judgments against foreign states.3
Statutory Background
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