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Baldwin v. Iowa State Traveling Men's
Association
283 U.S. 522 (1931)
Author: Jim
Facts: P brought action against D (an Iowa
company) in Missouri state court, which D successfully removed to
Missouri federal court. D made a special appearance to challenge
the service of process and personal jurisdiction. The court
denied the motion. D filed no answer and did not appear. The
court filed a judgment against D. P filed action against D in
Iowa to recover the Missouri Court's judgment but D again brought
the challenge to service of process and personal jurisdiction.
Issue: Whether the Missouri court's denial of D's
motion precluded the D from raising the same issue in Iowa court.
Holding: Yes
Rationale: Under the principle of res judicata,
once the D's motion was denied in Missouri's court, he was bound
by that ruling. D cannot raise the same issue in another court. D
could have fought the case in Missouri and then raise the issue
during appeals process in Missouri. But he did not. Therefore,
the Missouri court's ruling is binding.
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