Milliken v. Meyer
Headline: Wyoming judgment upheld; Court reversed Colorado and enforces out-of-state personal judgment, ruling substituted service on an absent domiciled defendant binds him in an oil-profit dispute.
Holding: The Court held that Wyoming validly exercised personal jurisdiction over Meyer through substituted service based on his Wyoming domicile, and Colorado must give full effect to the Wyoming in-personam judgment.
- States can bind domiciled residents through substituted service while temporarily absent.
- Colorado courts cannot cancel valid out-of-state personal judgments for internal inconsistencies alone.
- Makes it harder to avoid liability by relocating between states.
Summary
Background
Milliken claimed a share of profits from Colorado oil properties and sued to recover a 1/64th interest. A Wyoming court found Meyer had withheld that share, entered an in-personam money judgment against Meyer, and enjoined excess payments. Meyer was served under Wyoming’s substituted-service statute while he was physically outside Wyoming. Later a Colorado suit sought to declare the Wyoming judgment void, and the Colorado Supreme Court held the Wyoming decree void on its face because it saw an inconsistency in the Wyoming findings and decree.
Reasoning
The core question was whether Wyoming properly had personal jurisdiction over Meyer and whether Colorado could refuse to recognize the Wyoming judgment. The Court held Wyoming’s substituted service and statutory scheme satisfied due process because Meyer was domiciled in Wyoming and received notice by the method Wyoming authorized. Where a court of general jurisdiction has authority over a party, other States must presume the judgment valid and may not relitigate the merits or internal inconsistencies once jurisdiction is established. On the trial-court findings that Wyoming had jurisdiction, the Court reversed the Colorado Supreme Court and enforced the Wyoming judgment.
Real world impact
The decision protects out-of-state money judgments obtained under a state’s reasonable substituted-service rules when the defendant is domiciled there. Individuals who move or travel outside their home state remain subject to suits in their state of domicile if notice is reasonably given. The ruling limits state courts’ ability to nullify other states’ personal judgments based on internal contradictions rather than lack of jurisdiction.
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