Playnation Play Systems v. Guajardo

In Playnation Play Systems v. Guajardo, No. 13-06-00302-CV, 2007 WL 1439740 (Tex. App.--Corpus Christi 2007, no pet.), a Texas resident was sued in Georgia state court. In Georgia court, he filed a motion to dismiss for lack of jurisdiction, arguing that he was not subject to personal jurisdiction in Georgia. Id. The Georgia court disagreed and held that he had the requisite minimum contacts with Georgia for it to assert jurisdiction. Id. The Texas resident never appealed the ruling or appeared at the subsequent trial. Id. The judgment creditor then attempted to domesticate the Georgia judgment, but the Texas trial court found that the Georgia court lacked personal jurisdiction over the Texas resident and declared the Georgia judgment void. Id. The Playnation court first noted that pursuant to the Full Faith and Credit Clause, "when a challenge to a foreign court's judgment is made on jurisdictional grounds, the reviewing court is limited to inquiring as to whether the jurisdictional question was fully and fairly litigated and whether a final judgment as to the jurisdictional issue was rendered." Id. The court explained that the United States Supreme Court stated in Baldwin v. Iowa State Traveling Men's Ass'n, 283 U.S. 522 (1931), that "public policy dictates that there be an end of litigation; that those who have contested an issue shall be bound by the result of the contest, and that matters once tried shall be considered forever settled as between the parties." Thus, the Playnation court explained that after making sufficient jurisdictional inquiries, a court is constitutionally obligated to give "full faith and credit" to the merits issues decided by the foreign court. Id. And, pursuant to Baldwin, "if a defendant is unsatisfied with the foreign court's ruling as to jurisdiction, the proper redress is to appeal within the foreign court's judicial system." Id. "Texas applies the Baldwin precedent, and thus a properly proven foreign judgment must be recognized and given effect in a Texas court coextensive with that to which it is entitled in the rendering state." Id. "A Texas court must limit itself to the jurisdictional question, and must not investigate the merits of the sister state's decision." Id. . The Playnation court then explained foreign judgments filed pursuant to the UEFJA are presumed to be valid, the recitations of the judgment itself control the rest of the record, and extrinsic evidence may not be used. Id. Thus, a "collateral attack fails if the judgment contains jurisdictional recitals, even if other parts of the record show a lack of jurisdiction." Id. On appeal, the judgment debtor argued that the default Georgia judgment was void because the recitals on the face of the judgment did not assert the trial court's jurisdiction. The Playnation court disagreed, holding that the judgment's language appropriately recited jurisdictional facts. Id. Further, the Playnation court noted that "it is clear that the judgment debtor was given an opportunity to 'fully and fairly' litigate his claim under the Baldwin test." Id. The court noted that the judgment debtor had voluntarily entered a limited appearance and motion to dismiss for lack of jurisdiction in Georgia. Id. According to the court, there was no evidence that he was prohibited from presenting his case in the Georgia court, nor was there any evidence that he was not fully heard. Id. Further, the court noted that he had the right to appeal the judgment in Georgia, but chose not to exercise that right. Id. Thus, Playnation stands for the proposition that even when a judgment debtor raises the recognized exception that the sister state court lacked jurisdiction, if that judgment debtor had been afforded the opportunity to fairly litigate the jurisdictional issue in the sister court, he cannot raise it again in Texas.