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New York Life Insurance Company V. Dunlevy Revisited: The Power Of A Court To Exercise Jurisdiction For The Wrong Reason, Wilfred J. Ritz

Duquesne Law Review

Judgments can be divided into two classes: those that are valid and those that are void. Furthermore, according to Section 5 of the Restatement of Judgments: A judgment is void unless the State in which it is rendered has jurisdiction to subject to its control the parties or the property or status sought to be affected. The bases of jurisdiction, it is to be noted, are stated in the alternative - the parties or the property or the status. It is difficult to see how, in any realistic sense, a court can control property or status, without also having control …