Machado v. TaylorAnnotate this Case
A party’s delay in raising a challenge to the trial court’s subject matter jurisdiction is an improper ground on which to deny a motion for judgment of dismissal insofar as the motion challenged subject matter jurisdiction.
The Supreme Court reversed the judgment of the trial court in favor of Plaintiff in this negligence action. The trial court entered judgment after denying Defendant’s motion for judgment of dismissal raising a lack of subject matter jurisdiction. The Supreme Court held that the trial court’s stated rationale of delay and laches for denying the motion for judgment of dismissal was not a proper basis for denial. Rather, the trial court should have first resolved whether Defendant’s motion raised a colorable jurisdictional issue and, if so, whether it had jurisdiction over the cause of action. The court remanded the case for further proceedings.