Principle that state courts are deprived of subject-matter jurisdiction when principles of federal preemption are applicable; Ryan v. Brunswick Corp.; Sprietsma v. Mercury Marine; People v. Kanaan; Konynenbelt v. Flagstar Bank; Principle that an error in the exercise of a court’s subject-matter jurisdiction can be collaterally attacked; Bowie v. Arder; Workers’ Comp. Agency Dir. v. MacDonald’s Indus. Prod., Inc. (On Reconsideration); Principle that subject-matter jurisdiction cannot be granted by implied or express stipulation of the litigants; Harris v. Vernier; LLC v. Michigan Film Office

On remand from the Supreme Court, the court reversed the trial court’s order requiring defendant-ex-husband, under the offset provision in the parties’ consent judgment, to make payments to plaintiff-ex-wife to cover the reduction in his retirement pay, and remanded to the trial court. In the underlying action, both the trial court and the court enforced the plain terms of the consent judgment and required defendant to reimburse plaintiff for the reduction in her interest in his retirement benefits. The Supreme Court found that federal law preempted state law such that the consent judgment was unenforceable to the extent it required defendant to reimburse plaintiff for the reduction in the amount payable to her due to his election to receive certain military disability benefits. It then remanded for the court to address the effect of its holdings on defendant’s ability to challenge the terms of the consent judgment. On remand, the court held that “defendant did not engage in an improper collateral attack on the consent judgment and the trial court lacked subject-matter jurisdiction to enforce the consent judgment with respect to the offset provision due to the principle of federal preemption.”