Baldwin v. Iowa State Traveling Men’s Association
283 U.S. 522 (1931)
- Baldwin was trying to sue ISTMA. He sued in Missouri State Court. The suit was removed to Federal Court, and ISTMA successfully had this thrown out for lack of service of process.
- Baldwin tried again, and this time ISTMA tried to have the case thrown out for lack of personal jurisdiction. The Missouri Court found it had personal jurisdiction over ISTMA.
- ISTMA refused to appeal the finding that Missouri had personal jurisdiction. In fact, they refused to appear in court at all!
- ISTMA may have feared that appearances in court would be enough for Missouri to find that there was personal jurisdiction. (See Insurance Corp. of Ireland v. Compagnie des Bauxites (456 U.S. 694 (1982)).
- The Trial Court entered a default judgment against ISTMA after they declined to provide a defense.
- Baldwin sought to enforce the judgment in Iowa, since that’s where ISTMA was.
- ISTMA argued that Missouri never had personal jurisdiction over them, so the judgment was invalid.
- The Federal Appellate Court in Iowa agreed with ISTMA and threw out the judgment. Baldwin appealed.
- The US Supreme Court reversed the Iowa Court and reinstated the judgments.
- The US Supreme Court found that the issue of personal jurisdiction had been settled by res judicata and could not be reargued.
- Basically, since Missouri found that they had personal jurisdiction over ISTMA in the Trial Court, it was ISTMA’s duty to appeal that issue in Missouri at that time. Because ISTMA refused to appeal the issue in Missouri, the issue was closed. They could not later on re-raise the issue in an Iowa Court.