5. When a court has rendered a judgment in a contested action, the current view is that a judgment, otherwise valid and final, generally precludes the parties from litigating the question of the court’s subject-matter jurisdiction in a subsequent suit unless the court’s exercise of power was “a manifest abuse of authority,” or it “substantially” infringes upon another tribunal’s74authority,” or if the court lacked “capability to make an adequately informed determination.” Restatement (Second), Judgments § 12 (1982). See p. 354, infra.

Would this standard have affected the result in Des Moines?