York v. Texas
11 S. Ct. 9, 137 U.S. 15, 1890 U.S. LEXIS 2057 (1890)
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Rule of Law:
A state statute that treats a defendant's special appearance to challenge the court's personal jurisdiction as a general appearance, thereby submitting the defendant to the court's jurisdiction, does not violate the Due Process Clause of the Fourteenth Amendment.
Facts:
- J. H. York, a resident of St. Louis, Missouri, was alleged to be liable on two promissory notes.
- The holders of the notes filed a lawsuit against York in the District Court of Nolan County, Texas.
- York was not a resident of Texas and had not been found within the state.
- Notice of the lawsuit was served upon York in St. Louis, Missouri.
Procedural Posture:
- The plaintiffs sued York in the District Court of Nolan County, Texas.
- York, through his attorney, filed a plea solely to challenge the court's jurisdiction on the grounds of invalid out-of-state service.
- The trial court, applying Texas law, held that this special appearance constituted a general appearance, overruled the jurisdictional plea, and entered a judgment against York.
- York appealed to the Supreme Court of Texas, which affirmed the trial court's decision.
- York then sought a writ of error from the Supreme Court of the United States, arguing the Texas statute violated the Fourteenth Amendment.
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Issue:
Does a state statute that treats a special appearance to object to a court's jurisdiction as a general appearance, subjecting the defendant to that court's jurisdiction, violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Justice Brewer
No. A state statute that treats a special appearance as a general appearance does not violate the Due Process Clause of the Fourteenth Amendment. The court accepts the Texas Supreme Court's interpretation of its own statute. The core question is whether this procedure deprives a person of property without due process of law. The mere entry of a void judgment does not constitute a deprivation of property; deprivation only occurs when there is an attempt to enforce that judgment. A defendant in York's position has a viable alternative: he could have ignored the proceedings entirely. Had a default judgment been entered on insufficient service, it would be void. The defendant could then have protected his property by bringing an action to enjoin enforcement of the judgment or by asserting its invalidity as a defense in any other proceeding. The Texas statute merely removes the convenience of challenging jurisdiction without submitting to it; it does not eliminate the substantive right to due process, as avenues to challenge a void judgment remain. States have broad power to regulate procedure in their own courts, provided the substance of rights is secured.
Dissenting - Justices Bradley and Gray
Justices Bradley and Gray dissented without filing a written opinion.
Analysis:
This decision affirms the broad authority of states to regulate their own court procedures, even when those procedures diverge significantly from the federal standard or the majority of other states. It establishes a key distinction between procedural convenience and substantive due process rights, holding that forcing a defendant to choose between challenging jurisdiction (and submitting to it) or defaulting (and later attacking the void judgment) is not unconstitutional. The case legitimized the controversial 'Texas rule' on special appearances, emphasizing that due process is satisfied as long as a party has some ultimate opportunity to be heard before a final deprivation of property, even if that opportunity is not the most convenient one.
