Pan Energy v. Martin
In Pan Energy v. Martin, 813 P.2d 1142 (Utah 1991), the creditor filed an Oklahoma judgment in Utah one month before the end of the Oklahoma five year dormancy period.
The Utah court found that because the Oklahoma judgment was enforceable in Oklahoma at the time it was filed in Utah, it became a new Utah judgment on that date and was subject to Utah's 8 year period for enforcement. Id.
In Pan Energy v. Martin, the Court held that a judgment entered in a foreign jurisdiction and filed with the district court in Utah five years later could be enforced under the UFJA, "irrespective of the judgment's subsequent dormancy in the state of rendition." 813 P.2d at 1145.
In that case, Pan Energy Company (Pan Energy) had obtained a judgment against Martin in federal district court in Oklahoma in 1982. See 813 P.2d at 1143. In 1987, Pan Energy filed the Oklahoma judgment in the district court in Utah under the UFJA. See 813 P.2d 1142.
The judgment was later deemed unenforceable by the Oklahoma federal district court under Oklahoma's statute making judgments not executed upon within five years after the date of judgment unenforceable. See id.
Relying on this ruling, the Utah district court refused to allow enforcement of the foreign judgment in Utah, concluding that a foreign judgment that becomes unenforceable in the rendering state, even after filing in Utah, also becomes unenforceable in Utah. See 813 P.2d 1142.
The Court reversed, holding that a foreign judgment that is valid and enforceable when filed in this state is unaffected, for purposes of enforceability in Utah, if it "subsequently becomes dormant in the state of rendition." 813 P.2d at 1145.
The Court made clear in Pan Energy that a foreign judgment must be valid and enforceable in the rendering state at the time it is filed with the district court in Utah in order to be enforceable here under the UFJA.