Baldwin v. Iowa State Traveling Men’s Association Case Brief
Summary of Baldwin v. Iowa State Traveling Men’s Association, 283 U.S. 522 (1931)
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.
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.