IANAL, but the person terminated would probably have some pretty good arguments in a US based lawsuit. More money to be awarded by the court in case he wins too.
In the Netherlands court, the legal fees were sub 1k, and the decision happened less than 2 months from the filing.
Regardless, it would certainly be much more expensive in the US, where decent lawyers are hundreds or thousands an hour.
He spent time himself researching the law and going through the process, but he can't claim for that
It's not perfect but reasonably strong regulation of consumer insurance means that if you have problems with e.g the decision made, there is an independent organisation who can review the case for you.
You usually have to use a law firm which has an arrangement with the insurer, or one who will accept the lower rates the insurers have negotiated but again if you feel there is an issue with the quality on offer you can make a complaint.
I presume something similar is offered in NL.
It’s not unlikely the employee from the article used their services, even if just initially.
Case law is a thing in civil law systems too, it is just not binding on the judges except special occasions.
Here is some information I could find[1].
Obviously, there is a lot of variability here, and I don't there are blanket agreements to enforce judgements. It is hard to imagine the Netherlands forcing payment for an abortion damages judgement from a Texas court .
https://www.gibsondunn.com/wp-content/uploads/documents/publ...
The best option is to take the decision from jurisdiction B into a new court proceeding and jurisdiction A and ask them to honor it with a local court order in A.
They may or they may not.
Even within the United States you might have a court order in one state or payment, and another state that refuses to enforce it within their jurisdiction.
Except that that is often not the case, because of things like federalism, treaties and so on. Anyway, you're missing the point; you're now talking about a judgement from jurisdiction B, whereas earlier you were arguing that the rules from jurisdiction A could apply in jurisdiction B.
If a plaintiff goes to jurisdiction A with a judgement from jurisdiction B (eg pursuing the money as you suggested), you wouldn't retry the case under the rules of jurisdiction A. The reason is that the defendant (in this case the company headquartered in Florida qua jurisdiction A) agreed to the rules of the Netherlands (qua jurisdiction B) when it filed to get a business license there.
It would be different if a Dutch worker had sought employment with a company in Florida, and then complained when he didn't like the employment standards he found himself subjected to. It's the fact that the company committed itself to NL/EU law when opening a subsidiary there that subjects them to its judgments. The issue of the business license imposes conditions upon its beneficiary within the scope of its use.
Suppose something is legal your jurisdiction but not in mine. While you are in your jurisdiction, I can't sue or prosecute you for doing The Thing there. But if you come to my jurisdiction, do The Thing, and then return to your own, you can't shake off that liability because you don't get to bring your legal environment with you. The only exception I can think of offhand is with international diplomats, who get quasi-immunity because they are formally representing a different country, and whose embassies/consulates are allowed to operate under the law of their home rather than host countries.
>Juppor is talking about suing in Florida courts. Florida is absolutely at will. He may be able to sue to collect a foreign court judgement instead
Particularly relevant, is that if you want to collect in the US, you have to go to the courts in the US and show them the foreign judgment. There are many circumstances where these are not accepted.
>Juppor is talking about suing in Florida courts. Florida is absolutely at will. He may be able to sue to collect a foreign court judgement instead
If they are trying to avoid payment it will kink any activity in the EU, all over a relatively paltry sum.
The lesson though is that if you're dealing with potential shysters, like NFT promoters and other dodgy stuff this firm is doing (who else pays 70k Euro per year plus commissions to telemarketers??) then make sure they have assets in your jurisdiction that you can put a lien on, and ideally require cash up front.