I won a judgment in an Israeli court against someone who lives in the United States. Can I collect on it there?

The Israeli judgment is the easy part. A Tel Aviv Magistrates' Court gives you a money judgment against a former business partner, the Hotzaa LaPoal file opens, and then the enforcement officer establishes what you already suspected: the debtor left, the bank accounts are empty, and everything he owns is in Florida. An Israeli judgment has no force of its own outside Israel. What it has is evidential weight in an American court, and that is a different thing entirely.

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Detailed Answer

The United States has no bilateral treaty with Israel on the recognition of civil judgments, and no federal statute governs the question either. Recognition is a matter of state law, and most states have adopted either the 1962 Uniform Foreign Money-Judgments Recognition Act or the 2005 Uniform Foreign-Country Money Judgments Recognition Act; New York, for example, works through Article 53 of the Civil Practice Law and Rules. The mechanics are the same in outline everywhere: you file a fresh action in the state court, or in a federal court sitting in diversity applying that state's law, asking it to recognise the Israeli judgment. The American court does not retry the merits. It asks whether the Israeli judgment is final, conclusive and for a sum of money, whether the Israeli court had personal jurisdiction over the defendant, and whether any of the statutory grounds for refusal apply, chiefly lack of due process, fraud in obtaining the judgment, or repugnance to the public policy of the forum state. Israeli judgments generally clear these tests without difficulty, because the Israeli civil procedure a US judge examines looks recognisably like their own.

Two practical issues decide most of these cases, and both are handled in Israel before anything is filed in America. The first is the judgment package. You need a certified copy of the judgment from the issuing court, an apostille under the 1961 Hague Convention, which the Israeli courts issue on court documents for a fee of about NIS 41, and a complete English translation with a translator's certification. The second, and the one that quietly kills claims, is jurisdiction. If the defendant was served in Israel or appeared and defended, recognition is usually straightforward. If the Israeli judgment was given in default against someone who was living in the United States and was served under the Hague Service Convention or by substituted service, expect the American court to examine whether the Israeli court's exercise of jurisdiction met the forum state's minimum contacts standard, and expect the defendant's counsel to build the entire defence around that point. Time also matters: several states impose their own limitation period on recognition actions, commonly 10 or 15 years from the date the foreign judgment became effective. Our answer on apostilling an Israeli court judgment for use abroad covers the document step, and the mirror-image process is set out in our guide to enforcing a foreign judgment in Israel.

In Practice: No treaty governs Israeli judgments in the United States, so recognition runs through the forum state's Uniform Foreign-Country Money Judgments Recognition Act (in New York, Article 53 of the CPLR). Obtain a certified copy from the Israeli court plus an apostille at a court fee of about NIS 41 and a certified English translation, then file in the state where the debtor lives or banks. An unopposed recognition action commonly resolves in 3 to 4 months; a defended one on jurisdictional grounds runs 6 to 12 months with US legal fees frequently reaching USD 15,000 to USD 40,000, which is why judgments below roughly NIS 150,000 rarely justify the exercise.

When to Consult a Lawyer

• The Israeli judgment was given in the defendant's absence. Default judgments are where recognition actions are won and lost, and the Israeli service file needs to be assembled and translated in a form an American judge will accept before you commit to the filing.
• The debtor has moved assets between states or into a trust or LLC since the Israeli proceedings began. Recognition and collection are separate battles, and fraudulent transfer claims run on their own state timetables.
• Your Israeli judgment includes interest, linkage to the consumer price index or costs awards. American courts vary in how they convert and carry these forward, and the sum you plead at recognition is generally the sum you are stuck with.

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Speak With an Israeli Attorney

We prepare the certified and apostilled Israeli judgment package, evidence the service and jurisdiction record the American court will scrutinise, and coordinate with counsel in the debtor's state.

Contact us for a confidential initial consultation.