Waddle v. Sargent

I would first address the matter of “territorial jurisdiction” discussed in the majority opinion. Generally, territorial jurisdiction refers to a court’s authority to hear only cases that have some relationship to the geographical boundaries of that court’s jurisdiction. See Restatement (Second) of Judgments § 4 (1982). Lack of territorial jurisdiction will undisputedly void the judgment. That situation is clearly distinguishable from the one we have here where the court has proper jurisdiction in the above respect, but the trial itself is simply held in some other physical location. Under…