## Facts

- Louis Buttron sued El Paso Northeastern Railway Co. and two other railway companies in the district court of El Paso County, Texas, seeking damages for personal injuries allegedly caused by the defendants’ negligence in New Mexico.
- The defendants introduced in the Texas case a prior judgment from the Sixth Judicial District Court of the Territory of New Mexico that addressed the same injury claim.
- The New Mexico judgment arose from a territorial statute (Laws 1903, ch. 33) aimed at channeling New Mexico personal-injury disputes into New Mexico courts and setting conditions on liability for injuries inflicted in the territory.
- Among other things, the statute authorized an alleged wrongdoer, upon learning that a person claimed damages for a New Mexico injury, to file a petition in a territorial district court to require the claimant to appear and litigate the claim there.
- Acting under that statute, the railroads (defendants in Texas) initiated the New Mexico proceeding against Buttron to have his personal-injury claim determined in New Mexico.
- Buttron was a resident of the Territory of New Mexico and was personally served with process in the New Mexico case.
- Buttron did not appear in the New Mexico proceeding, and the territorial court rendered judgment against him and in favor of the railroads on the personal-injury claim.
- In the Texas suit, the trial court treated the territorial judgment as a valid, final adjudication of the same issues and directed the jury to return a verdict for the defendants.
- Buttron appealed, arguing that Texas should not treat the New Mexico judgment as barring his Texas personal-injury action, given the unusual statutory procedure used to obtain it.

## Issues

1. Whether Texas courts must recognize and give conclusive effect to a New Mexico territorial judgment—entered after personal service in a statutory proceeding initiated by the alleged tortfeasor—so as to bar a later Texas personal-injury suit based on the same injury.
2. Whether the New Mexico statute and resulting territorial judgment were so defective (including on constitutional grounds) that the Texas court could refuse to treat the judgment as binding.

## Decision

- The Texas Court of Civil Appeals affirmed the judgment for the defendants.
- The court upheld the trial court’s directed verdict, concluding that the New Mexico territorial court’s judgment was valid and final and had determined the claim Buttron later attempted to relitigate in Texas.
- Because Buttron was personally served in New Mexico and the territorial court had jurisdiction, Texas was required to treat the territorial judgment as conclusive and to bar the Texas action on the same cause of action.

## Legal Principles

- A final judgment from another jurisdiction, including a territorial court, is entitled to recognition in Texas when the rendering court had subject-matter jurisdiction and personal jurisdiction and the defendant received notice and an opportunity to be heard.
- A party who is personally served and then defaults generally remains bound by the resulting judgment; nonappearance does not make the judgment void.
- Claim preclusion applies when a prior final judgment between the same parties has already determined the same cause of action; a later damages suit based on the same injury is barred.
- Texas courts generally may not reject a sister-jurisdiction judgment based on disagreement with the other jurisdiction’s procedural mechanism, so long as jurisdiction and fundamental fairness requirements were satisfied.
- A legislature may attach conditions and local-forum requirements to a statutory right to recover for injuries occurring within its territory; judgments rendered under such a statutory scheme are enforceable elsewhere when jurisdictional prerequisites are met.

## Conclusion

Buttron’s Texas negligence suit was barred because the defendants had already obtained a final New Mexico territorial judgment—entered after personal service under a territorial statute allowing an alleged wrongdoer to compel litigation of the injury claim—and Texas was required to treat that judgment as conclusive between the parties on the same personal-injury cause of action.


Buttron v. El Paso Northeastern Railway Co., 93 S.W. 676 (1906)