The number of Americans convicted in foreign countries of criminal offenses has increased in recent years with the growth of the American presence overseas. As a result, American courts have been confronted with a substantial number of cases in which the prosecution has sought to introduce prior foreign convictions for collateral purposes. In Burgett v. Texas (1967), the Supreme Court held that a State violated due process by using a previous conviction secured in violation of due process to enhance punishment under a recidivist statute. The Court's precise rationale remains obscure, and if 'Burgett' is read to require that prior convictions be constitutionally proper, the use of all foreign convictions in American courts may be precluded. The article suggests that reliability is the proper standard for determining the permissible collateral use of foreign convictions and that wholly unfamiliar procedures used in many foreign forums meet that standard. At a minimum, a foreign conviction can be considered reliable only if it is reached after a formal inquiry has been convened and pursued. The absence of defense counsel in a foreign proceeding, although not conclusive of unreliability, should weigh heavily against treating the result as trustworthy. Evidence that the country surrounds its courts with some dignity and proceeds in a deliberate manner is the best initial test of whether the proceedings were conducted by an impartial tribunal which is dedicated to the factfinding process. Establishing that foreign procedures provide sufficient guarantees of reliability is primarily a theoretical exercise based on informed examination of the dynamics of the foreign criminal process and the role of specific procedures within it. Therefore, proper evaluation of a foreign conviction can take place within the domestic court with the help of expert witnesses and scholarly materials. The comment provides 119 footnotes.