Questão jurídica principal
Whether recognition of the Florida divorce judgment was barred by material public policy under Art. 27(1) PILA
Decisão extraída
No. The husband failed to show a violation of fundamental Swiss legal principles; any alleged income assessment error was attributable to his own refusal to produce financial documents, and the property division could not be reexamined on recognition.
Fundamentação extraída
The material public policy exception is narrow. The court held that using the wife's evidence after the husband's non-cooperation did not offend Swiss values, and that alleged errors in the matrimonial property allocation were matters for appeal, not recognition review.