In Re Marriage of Lyustiger

In this action based on the former Uniform Foreign Money-Judgments Recognition Act (Act; Code Civ. Proc., former § 1713 et seq.), Natalija Lyustiger (Wife) seeks to enforce two orders of a British domestic relations court requiring Nikolai Solomon Lyustiger (Husband) to pay a total of 50,000 British pounds for Wife’s attorney fees. After a trial in this enforcement action, the court determined that enforcement of the British orders was proper under the Act and entered judgment accordingly. We reverse. The Act specifically excludes from its scope the enforcement of “support in matrimonial or family matters,” and it applies a broad definition of “support.” (Code Civ. Proc., former § 1713.1, subd. (2).) The award of attorney fees was, for purposes of the Act, in the nature of “support”; therefore, the trial court erred by enforcing the award of attorney fees.

UNIFORM FOREIGN MONEY-JUDGMENTS RECOGNITION ACT

Wife brought this action pursuant to the Act. (Code Civ. Proc., former §1713 et seq. Further unspecified statutory references are to the Code of Civil Procedure.) Therefore, a summary of that law is in order.

In 1962, the National Conference of Commissioners on Uniform…