HI PHI FINANCIAL SERVICES INC v. James Lewis, Defendant. (2026)

On January 14, 2025, Plaintiffs Pioneer HI-Bred International, Inc. and PHI Financial Services, Inc. commenced this action against Defendant James Lewis demanding a judgment against Defendant in the sum of $178,176.00 plus interest "at the Iowa state rate of 18%" plus costs and disbursements. Plaintiffs allege that, they are entitled to a judgment in this amount because, on March 28, 2023, they obtained a judgment from Iowa State Court, Polk County, against Defendant in the sum of $178,176.00, and that Defendant has not made any payments in satisfaction of that judgment.

Defendant filed an answer on May 12, 2025, admitting to jurisdiction in Oneida County and asserting affirmative defenses, including that (1) Plaintiffs had not obtained jurisdiction over Defendant; (2) the judgment obtained in Iowa violated Defendant's due process rights because that court had not obtained jurisdiction over Defendant; (3) the Iowa judgment is invalid and unenforceable because no Notice of Entry was ever served on Defendant; and (4) the amount of the Iowa judgment was not accurately calculated.

Now, Plaintiffs move for summary judgment "for the sum certain amount of $178,176.00, the amount demanded in the Complaint" (Doc No. 11). In essence, Plaintiffs ask this Court to afford the Iowa judgment full faith and credit. Defendant did not file opposition to the motion for summary judgment. For the reasons that follow, Plaintiffs' request is denied.

Legal Analysis

The Full Faith and Credit Clause of the United States Constitution requires that a New York court afford the judgment of a sister State the same credit, validity, and effect that it would have in the State that rendered it (see U.S. Constitution, article IV, § 1; Boudreaux v State of La., Dept. of Transp., 11 NY3d 321, 325 [2008]). A default judgment of a sister State can be accorded full faith and credit (TCA Glob. Credit Master Fund, L.P. v Puresafe Water Sys., Inc., 151 AD3d 1098, 1099 [2d Dept 2017]). Review of the judgment of a sister State by the courts of this State is "limited to determining whether the rendering court had jurisdiction, an inquiry which includes due process considerations" (Ho v McCarthy, 90 AD3d 710, 711 [2d Dept 2011]). However, such an inquiry into the rendering court's personal jurisdiction over a defendant should only be made "where the defendant raises the issue of lack of personal jurisdiction" of the rendering court (id.).

Although Defendant did not oppose Plaintiffs' motion for summary judgment, in his answer, he asserted affirmative defenses, including lack of jurisdiction in the Iowa action and violation of his due process rights. "The proponent of a summary judgment motion must also demonstrate, prima facie, that the affirmative defenses raised by the opposing party are inapplicable" (South Nassau Med. Group, P.C. v 105 Rockaway Realty, LLC, 208 AD3d 812, 814 [2d Dept 2022]; see Munoz v City of New York, 237 AD3d 582, 583 [1st Dept 2025]). Defendant, in his answer, challenged both jurisdiction and due process, and to obtain summary judgment, Plaintiffs were required to demonstrate that Defendant's affirmative defenses are inapplicable. Plaintiffs did not do so.

Iowa's long-arm statute authorizes the widest exercise of personal jurisdiction allowed by the Due Process Clause (See Sioux Pharm. Inc. v Summit Nutritionals Int'l, Inc., 859 NW2d 182, 188 [Iowa 2015]; Ostrem v Prideco Secure Loan Fund, LP, 841 NW2d 882, 891 [Iowa 2014], citing Iowa R. Civ. P. 1.306). Thus, the proper due process analysis requires inquiry into "whether the defendant has sufficient 'minimum contacts with [the forum state] such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice' " (Sioux Pharm. Inc., 859 NW2d at 188, quoting Viasys., Inc. v EBM—Papst St. Georgen GmbH & Co., KG, 646 F3d 589, 594 [8th Cir. 2011]). The defendant must have sufficient contacts to " 'reasonably anticipate being haled into court' in the forum state" (Ostrem, 841 NW2d at 891—92, quoting World—Wide Volkswagen Corp. v Woodson, 444 US 286, 297 [1980]). Therefore, "it is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws" (Burger King Corp. v Rudzewicz, 471 US 462, 475 [1985]) (citation and internal quotation marks omitted).

On the record presented in this case, the Court cannot determine whether the Iowa court had personal jurisdiction over Defendant. Plaintiffs offer no evidentiary basis for a determination that Defendant had sufficient minimum contacts with the State of Iowa to satisfy due process. Although Plaintiffs need only make a prima facie showing, the Court finds that Plaintiffs' proof falls short of that standard.

After careful consideration of the papers identified at the outset of this Decision and Order, it is hereby

ORDERED that the motion for summary judgment is DENIED, without prejudice to renewal upon proper proof of personal jurisdiction over Defendant in the Iowa court.

This constitutes the Decision and Order of the Court.

ENTER:

Dated: 5/29/26

Utica, New York

Hon. Elizabeth Snyder Fortino, J.S.C.

Elizabeth Snyder Fortino, J.