Friday, December 27, 2013

Baldwin v. Iowa State Traveling Men’s Association case brief

Baldwin v. Iowa State Traveling Men’s Association case brief summary
283 U.S. 522 (1931)

CASE SYNOPSIS
Petitioner sought review of a judgment of the Circuit Court of Appeals for the Eighth Circuit, which affirmed a federal district court's dismissal of petitioner's action on a judgment rendered in a different federal district court. Petitioner contended that the lower courts improperly dismissed his case on grounds, among others, that respondent was barred by res judicata to relitigate the issue of jurisdiction.

CASE FACTS
Petitioner sought review of a judgment that affirmed a federal district court's dismissal of petitioner's action to enforce a judgment rendered in a different federal district court.

DISCUSSION
  • On certiorari, the Court reversed. First, the Court rejected petitioner's contention that the Full Faith and Credit Clause of U.S. Constitutional article IV, § 1 barred litigation of respondent's motion to dismiss the enforcement suit on grounds of lack of jurisdiction. 
  • The Court ruled that full faith and credit was not involved because neither of the courts concerned were state courts. 
  • The Court likewise rejected respondent's contention that to deny his defense of lack of jurisdiction would be a violation of due process under the Fourteenth Amendment, ruling that the Fourteenth Amendment did not concern the right to litigate the same question twice. 
  • Consequently, the Court ruled that because respondent specially appeared in petitioner's first action and moved for dismissal on grounds of lack of jurisdiction, a motion denied by the first district court, respondent was barred by res judicata from relitigating the jurisdiction issue in petitioner's second suit to enforce the judgment.
CONCLUSION
The Court reversed a judgment that affirmed dismissal of petitioner's action to enforce a judgment against respondent. The court remanded the cause for further proceedings in conformity with the Court's opinion.

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