Despite the Full Faith and Credit Clause of the U.S. Constitution, the Court of Appeals held that the enforcement of foreign judgments (in this case from Alabama) can be reviewed under Rule 60(b) on the following limited grounds:
(1) the judgment is based upon extrinsic fraud;
(2) the judgment is void; or
(3) the judgment has been satisfied, released, or discharged, or a prior judgment upon which it is based has been reversed or otherwise vacated, or it is no longer equitable that the judgment should have prospective application.
For a copy of the opinion, please see: