Des Moines Navigation & R.R. Co. v. Iowa Homestead Co.: Difference between revisions
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(Created page with "''Des Moines Navigation & R.R. Co. v. Iowa Homestead Co.'', 123 U.S. 552, 8 S.Ct. 217, 31 L.Ed. 202 (1887). '''FACTS:''' * Iowa Homestead (P) sued Des Moines (D) for unpaid...") |
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Revision as of 03:32, October 11, 2019
Des Moines Navigation & R.R. Co. v. Iowa Homestead Co., 123 U.S. 552, 8 S.Ct. 217, 31 L.Ed. 202 (1887).
FACTS:
- Iowa Homestead (P) sued Des Moines (D) for unpaid taxes – both citizens of Iowa; suit was brought in a state court
- Other defendants in the suit were citizens of NY, and moved to remove the suit to a federal court whole suit got moved into federal court even though there wasn’t complete diversity
- This issue was never addressed and the case made its way to SCOTUS with no discussion of jurisdiction
- P lost its suit with SCOTUS; tried to bring another action in Iowa state court against D (only Des Moines), claiming the federal verdict was null and void due to lack of proper subject matter jurisdiction
- Iowa courts bought it, even IA supreme court
PROCEDURAL HISTORY:
- P lost its suit with SCOTUS; tried to bring another action in Iowa state court against D (only Des Moines), claiming the federal verdict was null and void due to lack of proper subject matter jurisdiction
- IA courts went along with it; ruled in favor of P
- SCOTUS receives case again; considers its first decision not a nullity
ISSUE: Do cases that have been decided without proper jurisdiction, but are still in force, have res judicata?
HOLDING: (WAITE): Yes.
ANALYSIS:
- Cases have res judicata regardless of whether or not there was proper jurisdiction until the judgment/decision has been judicially annulled, vacated, or set aside.
- SCOTUS and federal courts are courts of limited not inferior jurisdiction
- If jurisdiction was not alleged in the proceedings, their judgments and decrees may be reversed for that cause on a writ of error or appeal, but until done so, they are conclusive between the parties and their privies
- Applies to cases in which jurisdiction was failed to be shown; no objection was made to jurisdiction
- Judiciary Act of 1789 was interpreted by SCOTUS to require complete diversity of citizenship for removal → diverse citizen must file and have the case removed to circuit courts; duty of the state court to halt proceedings
- NY citizens did the right thing, but the whole suit was moved to the circuit court; all parties
- Circuit Court should have remanded the case, or confined itself to that of between IA and NY citizens → if it kept it, it should have been reversed on appeal, as erroneous, but the decree would not have been a nullity
- P had every opportunity to object to jurisdiction and did not; thus, the suit was effectively settled → IA courts must give full faith and credit to federal court decisions
- Subject Matter Jurisdiction can be brought up and challenged at any time, even on appeal, by any party or the court itself → distinguishes it from personal jurisdiction (cannot be attacked collaterally in a separate, subsequent suit)
FINAL DEPOSITION: Reversed.
BLACK LETTER: Even cases that have been decided without proper jurisdiction have res judicata value, at least until they are judicially annulled, vacated, or set aside.
Res Judicata:
- once a judgment has been reached, the parties involved cannot try it again
- SCOTUS rules that its judgments are final, even in cases where it did not properly have jurisdiction
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