Law School Case Brief
Baldwin v. Iowa State Traveling Men's Asso. - 283 U.S. 522, 51 S. Ct. 517 (1931)
Public policy dictates that there be an end of litigation; that those who have contested an issue shall be bound by the result of the contest, and that matters once tried shall be considered forever settled as between the parties. There is no reason why this doctrine should not apply in every case where one voluntarily appears, presents his case and is fully heard, and why he should not, in the absence of fraud, be thereafter concluded by the judgment of the tribunal to which he has submitted his cause.
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 re-litigate the issue of jurisdiction.
Was the respondent barred by res judicata to re-litigate the issue of jurisdiction?
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 re-litigating the jurisdiction issue in petitioner's second suit to enforce the judgment, hence, the decision to dismiss the petitioner’s case is reversed.
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