| Venue: | SCOTUS |
| Facts: | Neff hires Mitchell, an attorney. Neff fails to pay Mitchell, and Mitchell sues. Neff is not a resident of Oregon, and was not served, and did not show for the lawsuit. Default judgment. Then Neff gets $15k worth of land in Oregon. Mitchell has the sheriff sell the land to satisfy the judgment. Pennoyer bought it, and got a deed from the sheriff. |
| Posture: | Neff sues Pennoyer in federal court to get the land back. |
| Issue: | Did the first suit and the sale of the land defeat Neff's title to it? |
| Holding: | No. Affirmed. |
| Rule: | The validity of a judgment depends on the jurisdiction of the court before it is rendered. For proceedings to be valid, they must take place within a tribunal competent to pass on the subject-matter of the suit. Defendants must get service within the state or appear voluntarily. |
| Reasoning: | If we allow judgments obtained in personam but based just on
publication notice, we're going to have total chaos with
states trying to give full faith and credit to each
others' fraudulent judgments.
States could make doing business contingent upon consent to jurisdiction. |
| Dicta: | |