On the Why American Courts Should Sometimes Consider Islamic Court Rulings thread, a commenter writes:
I think one consideration should be if the foreign court would honor a American court’s findings. This shouldn’t be a one-way street.
I suspect that most foreign countries are perfectly happy taking at face value American marriages and divorces between American citizens. But say that isn’t so — say, for instance, that Iran for some reason refuses to recognize American divorces.
Now say that Jane Doe, an American citizen, meets and marries Mohammed Moe, an Iranian refugee who has now become an American citizen. It turns out that decades ago, Moe had married Francoise Foe in France, Moe and Foe moved to Iran, and then Moe and Foe divorced in Iran. Everything was perfectly normal and aboveboard in all these transactions. You’d think the situation would be straightforward: Doe and Moe are to be treated as married under U.S. law, and this result would be in the U.S. legal system’s interests.
But under my correspondent’s proposal, Doe and Moe are not married, because Moe is still married to Foe. Moe’s French marriage to Foe is recognized (because France recognizes American marriages). But Moe’s Iranian divorce from Foe is not recognized (because, by hypothesis, Iran would not recognize American divorces). Doe and Moe thought they were married. They relied on their being married. It’s on balance good for U.S. to treat people like them as married, since legally recognized marriage is generally speaking socially valuable. But now they’re not married, not because of any fault of their own but because of the stupid rules of Iran. And remember that Jane Doe had never even been to Iran; why should she suffer as a result of the hypothetical Iranian refusal to recognize American decisions?
Does that [...]