Mayekawa Manufacturing Co., Ltd. v. Sasaki

In Mayekawa Manufacturing Co., Ltd. v. Sasaki (1995) 76 Wn. App. 791 888 P.2d 183, the Washington code provided for recognition of foreign judgments that are " 'final and conclusive and enforceable where rendered.' " (Id., 888 P.2d at p. 187.) There is no mention of an appellate caveat in the Washington code quoted in Mayekawa. The Mayekawa court held that because the Japanese Civil Code stated that a judgment shall not become final and conclusive if an appeal or objection is filed, a Japanese " 'preliminarily enforceable' " judgment for which an objection had been filed could not be recognized by the Washington court even though it was enforceable. (Ibid.)