OK, folks. Time to get some perspective here. I will endeavor to point out some things for those of you who are not too far gone to understand.
First, why does it matter that Justice of the Peace Mahoney had died when the Minnesota Supreme Court tossed out his decision? When has it ever been a rule that the judge or judges who rendered a decision must still be breathing in order for that decision to be overturned? Think about the landmark case of Brown v. Board of Education, the U.S. Supreme Court case that did away with school segregation in 1954. That case overturned a previous Supreme Court decision, Plessy v. Ferguson, which had been decided in the 1890s. Do you really think any of the justices on the Plessy court were still alive in 1954?
Second, justice of the peace courts are typically the lowest rank of court in any state. They are courts of limited jurisdiction, usually are not even considered courts of record, and many states allow people to be justices of the peace who have no legal training whatsoever. Mahoney didn't. He was a farmer and carpenter. Speaking to my own experience in Georgia, we have magistrate courts in every county which correspond to justice of the peace courts in other states. Their jurisdiction is very limited, a person can be a magistrate with just a high school education, and every decision by a magistrate is appealable de novo to a higher court in the same county.
Third, Mahoney's decision was completely beyond the powers of a justice of the peace under Minnesota law. As the Minnesota Supreme Court noted in one of the cases associated with Credit River, In re Daly, 284 Minn. 567, 171 N.W.2d 818 (1969):
Quote:
In Minnesota, the justice of the peace court is a court of inferior jurisdiction. [1] Since the constitutional amendment of the judicial article in 1956 justice of the peace courts exist in this state only to the extent permitted by the legislature. Minn.Const. art. 6, §§ 1, 8, and Schedule. The legislature has fixed narrow limits to the jurisdiction which may be exercised by justices of the peace in this state. (Minn.St. 530.01, 530.05, 530.06, 531.03, 531.04, 532.37.) Acts in excess thereof by such justices of the peace are a nullity and subject to control by a writ of prohibition. Smith v. Tuman, 262 Minn. 149, 114 N.W.2d 73.
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Id., 284 Minn. at 569, 171 N.W.2d at 821
Quote:
In the matter before us it was evident [284 Minn. 570] from an examination of the summons and complaint in the proceedings sought to be restrained that Justice of the Peace Mahoney was undertaking to act in a matter with respect to which he had no jurisdiction. The representation of an attorney at law authorized to practice before this court that a copy of this summons and complaint attached to the petition seeking the writ of prohibition was a true and correct copy of the process served on his client formed in itself an adequate factual basis for the issuance of the temporary order directed to Justice of the Peace Mahoney and Jerome Daly.
(5) The refusal of the justice of the peace to respect the July 11 order of this court was not justified. The justice of the peace would be bound to obey our intermediary order regardless of whether the actions restrained by our order were in excess of his jurisdiction. In re Lord, Supra. Apart from this principle, it is clear that the proceedings restrained were beyond the limits of the jurisdiction of the justice of the peace in a number or respects, including these:
(a) The summons, being returnable at 7 p.m. rather than between the hours of 9 a.m. and 5 p.m. as specified by Minn.St. 531.03, was a nullity.
(b) The summons did not contain a statement of the amount claimed by plaintiff as required by § 531.03.
(c) Contrary to the provisions of § 531.04, the summons was personally served upon Northwestern National Bank of Minneapolis in the city of Minneapolis, a city having a population in excess of 200,000.
(d) This service was performed outside of the county of issuance, Scott County, in violation of the provision of § 531.04 that such service must satisfy the requirements of Minn.St. 532.29. One of the requirements of Minn.St. 532.29 is a continuance of proceedings for a period not exceeding 20 days, and no such continuance was provided in this case.
(e) The amount in controversy exceeded the $100 jurisdictional limitation of the justice of the peace courts under § 530.05.
(f) The relief sought, a declaratory judgment, was not within the granted powers of a justice of the peace. See, § 530.05. It has been the law ever since the 1861 case of Fowler v. Atkinson, 6 Minn. 350 (503), that a justice of the peace has no jurisdiction over equitable proceedings. See, Smith v. Tuman, Supra.
Id., 284 Minn. at 569-570, 171 N.W.2d 822.
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