The judgment of a court ot record and of general jurisdiction, acting within the scope of its jurisdiction, is presumed to be valid in all particulars unless the contrary affirmatively appears on the face of the record. But even such a judgment is subject to attack on the ground of lack of jurisdiction. The judgment of a court of limited jurisdiction and not of record enjoys no such presumption, and the jurisdiction of such a court must be affirmatively shown. In this state, a justice court is not, and cannot be made, a court of record, and its jurisdiction is limited both as to subject matter and as to territory. Yet in a recent case the Supreme Court upheld, against a direct attack, the validity of a default judgment in a justice court against a defendant residing and served outside its territorial jurisdiction.
H. C. Force,
Notes and Comments,
Jurisdiction of a Justice of the Peace,
2 Wash. L. Rev.
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