BANK MELLI IRAN; BANK MELLAT, Plaintiffs-Appellants, v. SHAMS PAHLAVI, aka H.I.H. Princess Shams Pahlavi, Defendant-Appellee., 58 F.3d 1406

Summary

Appellant banks filed an action seeking the enforcement of judgments against appellee, a member of the Iranian royal family, pursuant to the Algerian Accords and the California Uniform Foreign Money-Judgments Recognition Act (Act), Cal. Civ. Proc. Code §§ 1713-1713.8. Appellants had obtained default judgments against appellee on her promissory notes in the Iranian courts. The district court granted summary judgment in favor of appellee and the court affirmed. Sufficient evidence sustained appellee's assertion that the judgments were unenforceable because they were rendered without due process. The Iranian courts were highly politicized, hostile, and non-independent entities that rarely conducted public trials. Neither the Act nor the Algerian Accords, which authorized the recovery of assets from the Iranian royal family, allowed for enforcement of judgments entered without due process.