Daily Decisions: Court of Appeals Again Clarifies Subject Matter Jurisdiction

There are a lot of facts in MHM&F, LLC v. Edward Pryor, Jr. (Division 1, May 21, 2012), but none of them really matter. The short story: Pryor owed money on a mobile home space, he didn’t pay, so the plaintiff filed an unlawful detainer action against him. Pryor lost.

On appeal, Pryor raised two issues that he failed to raise in the trial court: (a) that the wording on the summons was defective and (b) that the mobile home association for the group of lots should have been named as a necessary party. Pryor claimed his failure to raise these issues below was not fatal because they both went to the trial court’s subject matter jurisdiction.

The Court of Appeals disagreed, despite noting prior cases that used the language of “jurisdiction” when referring to the wording of a summons or the joinder of a necessary party in a mobile home case. “But those cases are incorrectly reasoned on that point” because they “did not consider article IV, section 6 of our constitution.” Nor did they consider more recent cases which have “overruled precedents that erroneously classify the superior court’s jurisdiction as statutory.”

The Washington Supreme Court has “observed that the improvident and inconsistent use of the term ‘subject matter jurisdiction’ has caused it to be confused with a court’s authority to rule in a particular manner.” “Whether the superior court ruled correctly or incorrectly in this particular case, it did not lack subject matter jurisdiction.  The court’s subject matter jurisdiction in cases involving the title or possession of real property is expressly granted by the state constitution and has not been ‘vested exclusively in some other court.’” (quoting Wash. Const. art. IV, sec. 6.)

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4 thoughts on “Daily Decisions: Court of Appeals Again Clarifies Subject Matter Jurisdiction

  1. The court writes “Thus, it is incorrect to say that the court acquires subject matter jurisdiction from an action taken by a party or that it loses subject matter jurisdiction as the result of a party’s failure to act.” But isn’t this in error? Consider the rule that administrative appeals must be filed in a timely manner in order to confer SMJ in the trial court – doesn’t that mean that the trial court acquired SMJ “from an action taken by a party”?

  2. If you’re talking about federal district courts, my sense is that SMJ is much more limited and more subject to statutory modification (regarding administrative filings, etc.) in federal court than in Washington State. Under Washington law, the state constitution includes a broad grant of subject matter jurisdiction to the trial courts, vesting them with constitutional SMJ in
    “all cases and of all proceedings in which jurisdiction shall not have been by law vested exclusively in some other court.” According to the case law, the entire point of this constitutional grant of jurisdiction is to avoid the sort of statutory whittling away of trial court jurisdiction that is so common in the federal courts. So Washington cases make a big distinction between statutory limits on “authority” and actual jurisdiction (in the sense that the failure of authority can be waived while the lack of SMJ cannot). So, for instance, in a prior case there were all sorts of statutory timing limits on how long a party had to file certain kinds of divorce proceedings. But the violation of that time limit was not reviewable on appeal because it was (a) not raised below and (b) not jurisdictional because the superior courts have SMJ over family law matters.

    Now, once the legislature creates a separate “exclusive” forum/agency for jurisdiction over certain types of claims, I’m not quite sure how much leeway the legislature (or the agency itself) has to great “jurisdictional” rules for the various levels of review that might exist such a forum. The only case I know on that point had to do with whether an error by the Board of Industrial Insurance Appeals was jurisdictional. The Court of Appeals sort of recognized that the Board made an error, in deciding a question that was not properly before it, but concluded that “a tribunal lacks subject matter jurisdiction only when it attempts to decide a type of controversy over which it has no authority to adjudicate.” Since the Board had jurisdiction over the “type” of controversy at issue (a workers’ comp claim) it did not lack SMJ despite its possible error in reaching an un-raised question.

  3. Pingback: Daily Decisions: Jurisdiction Revisited (and Muddled) | Ziff Blog

  4. Pingback: The [No Specific Day] Mash-up: June 1, 2012 | Ziff Blog

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