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
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