Landstar Global Logistics, Inc. v. Robinson & Robinson, Inc.

In this appeal from postjudgment orders directing issuance of a letter rogatory requesting registration of judgment liens against properties of the judgment debtor in Mexico and restraining the debtor from transferring its right to payment upon the sale of those properties, we must decide two issues of first impression in California. First, may a court request the registration of judgment liens in a foreign country via a letter rogatory issued pursuant to the Inter-American Convention on Letters Rogatory? Second, may a court issue an order restraining the disposition of a right to payment pursuant to Code of Civil Procedure section 708.520 when it has not previously or simultaneously issued an order assigning the right to payment pursuant to section 708.510 of that code? We answer both questions in the negative and therefore reverse the challenged orders.

I.

BACKGROUND

A. The Litigation Against Robinson & Robinson, Inc.

There are three lawsuits pertinent to the issues involved in this appeal:

First, Landstar Global Logistics, Inc. (Landstar), filed an action in the San Diego County Superior Court to domesticate and enforce a judgment it had obtained against Robinson…