California divorce judgments are binding and enforceable within the United States
under the Full Faith and Credit Clause of the U.S. Constitution and 28 U.S.C. Section 1738. However, when enforcement or recognition is sought abroad — for example, in the U.K., France, or Iran — the legal landscape changes entirely. Recognition becomes a matter of foreign law, not California law. International instruments (such as the Hague Conventions) and bilateral agreements (where they exist) play a critical role. This article surveys the principal approaches taken in common law, civil law, and Islamic law jurisdictions, with practice notes emphasizing recognition in Iran.
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From Sacramento to Shiraz: Practical steps for registering California divorce judgments abroad
This article was previously published, and reproduced with permission.
Hadjian, Abbas. (2025, November 25). From Sacramento to Shiraz: Practical steps for registering California divorce judgments abroad. The Daily Journal. https://www.dailyjournal.com/articles/388754-from-sacramento-to-shiraz-practical-steps-for-registering-california-divorce-judgments-abroad.