Although the judgments and decrees of the Circuit Courts may be erroneous, if the records fail to show the facts on which the jurisdiction of the court rests, such as that the plaintiffs were citizens of different States from the defendants, yet that they are not nullities, and will bind the parties until reversed or otherwise set aside.
In an action in equity that was brought by plaintiff homestead company against defendant railroad company to recover the same taxes for the years 1864 to 1871 that formed part of the subject matter of a prior litigation between the same parties, the railroad company challenged, by writ of error, a decision of the Supreme Court of the State of Iowa, which found for the homestead company. Defendant railroad company set up the prior adjudication as a bar to the action. Plaintiff homestead company contended that the decree was null and void because the courts of the United States had no jurisdiction of the suit. The Court reversed the judgment and remanded the cause for further proceedings that were not inconsistent with the Court's opinion.
Did the court have jurisdiction to entertain and finally dispose of the suit in which the prior adjudication was had?
In reversing and remanding, the Court found that the parties appeared in the circuit court without objection. The circuit court proceeded as if its authority in the matter was complete. Whether the suit could be removed was a question for the circuit court to decide when it was called on to take jurisdiction. If it kept the case when it should have been remanded or if it proceeded to adjudicate upon matters in dispute between two citizens of Iowa when it should have confined itself to those between the citizens of Iowa and the citizens of New York, its final decree could have been reversed on appeal as erroneous. The Court determined that the decree would not have been a nullity. The circuit court entertained the suit. The Court impliedly recognized its right to do so on appeal. The Court's decree could not be deemed a nullity. It was a valid and subsisting prior adjudication of the matters in controversy that bound the parties and was a bar to the action.