We were counsel for Olympic View Water and Sewer District in Ronald Wastewater District v. Olympic View Water & Sewer District. Benjamin Gould’s article in NWSidebar suggesting the Supreme Court’s reasoning in that case departed from past decisions of the court on subject-matter jurisdiction, fails to acknowledge supportive Supreme Court precedent.
Washington law has long understood that the analysis of a judgment’s validity is not confined merely to analyzing personal and subject-matter jurisdiction. John Hancock Mut. Life Ins. Co. v. Gooley, 196 Wash. 357, 370, 83 P.2d 221 (1938) (recognizing that there are three jurisdictional elements to any valid judgment—“jurisdiction of the subject matter, jurisdiction of the person, and the power or authority to render the particular judgment.”); Dike v. Dike, 75 Wn.2d 1, 7, 448 P.2d 490 (1968). The court’s decision is grounded in Washington law of more than eight decades duration. The court’s John Hancock decision itself was based on treatise authority.
Without mentioning these cases, the court’s Ronald Wastewater opinion was foreshadowed in Banowsky v. Backstrom, 193 Wn.2d 724, 445 P.3d 543 (2019) when it ruled that a district court lacked subject-matter jurisdiction in a civil case where damages exceeded the statutory limit of $100,000. Obviously, a district court had subject-matter jurisdiction to adjudicate the type of case generally, civil cases; it lacked the requisite authority to adjudicate cases exceeding the statutory limit.
The court applied a sensible rule on the validity of a judgment. A court may have personal jurisdiction over the parties and subject-matter jurisdiction to adjudicate certain types of claims in general terms, but it may still lack express authority from the Legislature or common law to render the judgment in question.