Duhaime's Law Dictionary

Calvo Clause Definition:

Mexican real estate law that requires that any action challenging the title of real property situated in Mexico must be litigated in Mexico and exclusively governed by Mexican law.

In Icenhower, Justice DeCarl Adler explained the Calvo Clause as follows:

"The Calvo clause is a doctrine of Mexican law which holds that judgments rendered by foreign courts purporting to affect title to real property in Mexico are unenforceable as against the public interest in Mexico, and contrary to the exclusive sovereignty of Mexico over its realty. In essence, it is an automatic forum selection clause in favor of Mexico."


  • In re Icenhower, 398 BR 902 (United States Bankruptcy Court, California, 2008). See footnote 29.

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