Judgments can be divided into two classes: those that are valid and those that are void. Furthermore, according to Section 5 of the Restatement of Judgments: A judgment is void unless the State in which it is rendered has jurisdiction to subject to its control the parties or the property or status sought to be affected. The bases of jurisdiction, it is to be noted, are stated in the alternative - the parties or the property or the status. It is difficult to see how, in any realistic sense, a court can control property or status, without also having control over at least one of the parties, for some person must act to bring the property or status under a court's control. It, therefore, would be more accurate to say that a judgment is void unless the state, that is, a court has subjected the parties, or at least one party and the property, or at least one party and the status to its control.
Wilfred J. Ritz,
New York Life Insurance Company v. Dunlevy Revisited: The Power of a Court to Exercise Jurisdiction for the Wrong Reason,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol3/iss1/4