Renda

In this case we hold that Code of Civil Procedure section 1710.40 is the proper means to challenge registration of a sister state judgment on jurisdictional grounds, its 30-day limitations period is inapplicable to challenges based on lack of fundamental jurisdiction, and the trial court did not err in ruling that the sister state default judgment against Mario Renda was void.

Airlines Reporting Corporation (Airlines Reporting) obtained a $2.5 million default judgment against Renda in Virginia and registered it in California pursuant to the Sister State Money-Judgments Act. (Code Civ. Proc., § 1710.10 et seq.; undesignated statutory references are to the Code of Civil Procedure.) Renda successfully challenged registration of the sister state judgment on grounds the Virginia state court lacked personal jurisdiction over him. Airlines Reporting appeals, arguing that the trial court erred in finding that (1) the 30-day limitations period imposed by section 1710.40, subdivision (b) was inapplicable to Renda’s motion to vacate the Virginia judgment and (2) Renda did not waive his jurisdictional defense by filing a notice of appearance and responding to postjudgment discovery.…