Milliken v. Meyer
The Supreme Court ruled that Wyoming's courts had valid personal jurisdiction over a man who was domiciled there even though he was served with the lawsuit papers while he was physically in Colorado, because Wyoming's substitute-service method gave him real notice and a chance to respond.
The decision reversed the Colorado Supreme Court, which had thrown out the Wyoming judgment on other grounds, and reaffirmed that a state's authority over its own residents does not evaporate just because they happen to be traveling or living elsewhere temporarily.
“Enjoyment of the privileges of residence within the state, and the attendant right to invoke the protection of its laws, are inseparable”
Explains why domicile carries duties as well as benefits, including being subject to suit.
How it got here: The Colorado Supreme Court voided a Wyoming judgment against Meyer; Milliken sought Supreme Court review, which was granted to resolve the federal full-faith-and-credit question.
The Case in Depth
What happened
The case grew out of a dispute over a small share of profits from Colorado oil properties. Milliken claimed a portion of Meyer's interest in those profits, and after a settlement fell apart, Milliken sued Meyer and an oil company in Wyoming, alleging fraud. Meyer, said to be a Wyoming resident, was personally served with the Wyoming lawsuit papers while he was in Colorado, but he never appeared in the case, and Wyoming entered a money judgment against him.
The question before the Court
If a person is legally domiciled in a state but happens to be served with a lawsuit while temporarily outside it, can that state's court still issue a valid personal judgment against him?
Why it matters
People who are domiciled in one state but temporarily away from it can still be sued there and bound by the resulting judgment, as long as the state uses a service method reasonably likely to notify them. This gives states a reliable way to hold their residents accountable in court disputes over property and money even when those residents are elsewhere when the suit is filed.
What changes now
The Supreme Court's reversal restores the validity of the Wyoming judgment against Meyer, undoing the Colorado Supreme Court's decision that had declared it void. The case does not appear to require further proceedings on the jurisdictional question, since the Court resolved that issue directly; any remaining disputes over the profits and payments would proceed consistent with the Wyoming judgment being given full faith and credit in Colorado.
What this does not decide
The Court's ruling rests specifically on Meyer's Wyoming domicile and the particular substituted-service statute Wyoming used; it does not decide whether other forms of substituted service, or service on someone without an established domicile in the forum state, would meet due process.
How the Court got there
The legal reasoning, step by step
- The Court explained that when a judgment from one state is challenged in another, courts may still ask whether the first court actually had jurisdiction over the person or the subject matter — that inquiry is always allowed.
- But if the judgment looks on its face like the record of a court with general authority to hear such cases, jurisdiction is presumed unless disproved by outside evidence or the record itself, and once jurisdiction is established, the full faith and credit rule bars any second-guessing of the merits, the legal reasoning, or apparent inconsistencies between findings and the decree.
- Applying this, the Court found that the Colorado Supreme Court had improperly voided the Wyoming judgment based on an inconsistency in the Wyoming court's reasoning rather than on any actual lack of jurisdiction.
- The Court then examined whether Wyoming had jurisdiction over Meyer and concluded that being domiciled in a state is itself enough to subject an absent person to that state's courts for a personal judgment, so long as the method used to notify him was reasonably likely to reach him.
- Because Wyoming's law allowed personal service outside the state on someone domiciled within it, and Meyer received actual notice through that method, the Court held the notice satisfied due process's requirement of fair play and a real chance to be heard.
- The Court reasoned that the duties of state citizenship, including being subject to suit through reasonable substituted service, flow from domicile itself and are not erased by temporary absence from the state.
Doctrinal impact
Cases affected by this decision
Reaffirms Adam v. Saenger (303 U.S. 59)
Reaffirmed that a judgment appearing to be from a court of general jurisdiction is presumed valid unless disproved.
Reaffirms Fauntleroy v. Lum (210 U.S. 230)
Reaffirmed that a valid judgment is conclusive on the merits regardless of legal errors underlying it.
Reaffirms McDonald v. Mabee (243 U.S. 90)
Relied on to show substituted service can satisfy due process if reasonably calculated to give notice.