Panagiota M. Costaras v. Basilios C. Costaras

Phoenix, Arizona family law divorce lawyers represented the parties in a dissolution action.



The issue before us is to what extent the Full Faith and Credit Clause of the United States Constitution, U.S. Const. art. 4, § 1, and A.R.S. § 12-544(3) obligate Arizona courts to enforce a domesticated revived judgment issued by a court in another state. We hold that if the laws of the state of rendition treat a revived judgment as a new judgment, Arizona's foreign judgment limitation statute begins to run anew with the revived judgment. Here, because Ohio law treats a revived judgment as a new judgment, A.R.S. § 12-544(3) began to run anew with the issuance of the revived judgment by the Ohio court. Accordingly, we vacate the superior court's order vacating the domestication of the Ohio revived judgment and quashing the associated writ of garnishment, and remand for proceedings consistent with this opinion.

Costaras v. Costaras, 1 CA-CV 23-0286 (Ariz. App. Mar 07, 2024)

We vacate the superior court's order vacating the domestication of the Revived Judgment and quashing the associated writ of garnishment, and remand for proceedings consistent with this opinion.