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Difference between revisions of "Des Moines Navigation & R.R. Co. v. Iowa Homestead Co."

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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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'''HOLDING:''' (WAITE): Yes.  
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'''HOLDING:''' (Chief Justice Waite): Yes.  
  
  

Latest revision as of 02:36, 11 October 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: (Chief Justice Waite): Yes.


ANALYSIS:

  1. 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.
    1. SCOTUS and federal courts are courts of limited not inferior jurisdiction
    2. 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
    3. Applies to cases in which jurisdiction was failed to be shown; no objection was made to jurisdiction
    4. 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
      1. NY citizens did the right thing, but the whole suit was moved to the circuit court; all parties
      2. 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
    5. 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
  2. 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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