Civil Procedure · procedure

Elements of Collateral Attack

Quick Answer

What are the elements of Collateral Attack?

A collateral attack is an attempt to challenge the validity of a prior court judgment or order in a subsequent case, typically aimed at preventing the enforcement of that judgment. This approach can be employed when the challenging party did not have a full and fair opportunity to contest the original ruling.

Required Elements

1. Prior Judgment

There must be an existing judgment or adjudication from a competent court.

What to prove: The challenger must demonstrate that a specific judgment exists that they wish to contest.

2. Lack of Personal Jurisdiction (or Invalidity)

There must be valid grounds for claiming that the prior judgment is invalid, such as lack of personal jurisdiction, or other due process violations.

What to prove: The party must show that the original court lacked proper authority or there were procedural defects that invalidated the judgment.

3. Separate Proceeding

The attack must be raised in a distinct legal proceeding rather than through the regular appellate process.

What to prove: The challenger must initiate an entirely separate lawsuit or action to bring forth the collateral challenge.

Burden of Proof

The burden of proof lies with the party making the collateral attack, typically requiring them to establish their claims by a preponderance of the evidence.

Available Defenses
  • Res judicata
  • Estoppel
Common Fact Patterns
  • A defendant in a foreclosure case seeks to challenge the earlier judgment by claiming the court lacked jurisdiction.
  • An individual tries to collaterally attack a divorce decree in a custody case, arguing that they were not properly served.
Exam Tip

Students should be prepared to analyze scenarios involving prior judgments and consider whether a collateral attack is appropriate, focusing on jurisdictional issues and procedural validity.

Key Cases
  • U.S. v. McGowan
  • Parker v. Walker
  • Baker v. Goldfield

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