James K. Collins v. D.R. Horton-Texas Limited

The Fourteenth Amendment protects citizens against takings of property without due process. Due process includes, at a minimum, personal jurisdiction, notice, and an opportunity to be heard. Can a judgment of a court that undisputedly lacked personal jurisdiction over a citizen nevertheless be the sole basis for taking his real property? Under the Supremacy Clause, federal courts have final authority to determine the constitutionality of statutes and their own court actions, and this Court holds that Fed. R. Civ. P. 60 vests sole authority to revisit the judgment of a federal court in the originating federal court. Could the actions of a state court or a res judicata holding estop a citizen from bringing a suit to vacate a federal judgment—void for want of personal jurisdiction—in the originating federal court? Circuit courts are irreconcilably split on this issue.