## Facts

- Baldwin obtained a money judgment against the Iowa State Traveling Men’s Association, an Iowa corporation, in the U.S. District Court for the Western District of Missouri.
- In the Missouri case, the Association appeared specially to challenge personal jurisdiction based on allegedly defective service.
- The Missouri court initially quashed service but did not dismiss; after an alias summons, the Association again specially appeared to set aside service and dismiss for lack of personal jurisdiction.
- After briefing and a hearing, the Missouri court overruled the jurisdictional motion and granted the Association time to plead.
- The Association filed no pleading on the merits, took no further action, and did not seek post-judgment relief or appellate review; judgment was entered for Baldwin.
- Baldwin then sued in the U.S. District Court for the Southern District of Iowa to enforce the Missouri federal judgment.
- The Association again asserted lack of personal jurisdiction in Missouri; the Iowa district court accepted the defense and dismissed, and the Eighth Circuit affirmed.

## Issues

1. Whether a defendant that fully litigated personal jurisdiction in the rendering federal court, then allowed a merits judgment to become final without review, may collaterally attack that judgment for lack of personal jurisdiction in a later federal enforcement action.
2. Whether barring relitigation of personal jurisdiction is required or forbidden by the Full Faith and Credit Clause or by due process.

## Decision

- The Supreme Court reversed.
- The Missouri federal court’s determination of personal jurisdiction, reached after the Association’s special appearance and full hearing, was res judicata and could not be collaterally attacked in the Iowa enforcement action.
- The Full Faith and Credit Clause does not apply to federal courts.
- Due process was satisfied because the Association had a full and fair opportunity to litigate jurisdiction in Missouri and had available routes for direct review.

## Legal Principles

- When a defendant specially appears in a federal court to contest personal jurisdiction, is fully heard, and the objection is overruled, a later merits judgment that becomes final is conclusive on personal jurisdiction in subsequent enforcement litigation.
- A party is not entitled to relitigate a jurisdictional issue that was already decided after a full and fair opportunity to be heard; the proper remedy is direct review in the original proceeding.
- The Full Faith and Credit Clause governs interstate effect of state judgments and does not directly govern recognition of federal judgments by other federal courts.
- Due process requires an opportunity to be heard, not repeated litigation of the same jurisdictional question in successive forums.

## Conclusion

Because the Association fully litigated personal jurisdiction in the Missouri federal action and did not pursue direct review after losing, the Missouri judgment was binding on the jurisdictional issue and could not be collaterally attacked in the later federal enforcement suit in Iowa.


Baldwin v. Iowa State Traveling Men’s Ass’n, 283 U.S. 522 (1931)