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Law School Case Brief

Martin v. Wilks - 490 U.S. 755, 109 S. Ct. 2180 (1989)

Rule:

One is not bound by a judgment in personam in a litigation in which he is not designated as a party or to which he has not been made a party by service of process. This rule is part of the deep-rooted historic tradition that everyone should have his own day in court. A judgment or decree among parties to a lawsuit resolves issues as among them, but it does not conclude the rights of strangers to those proceedings

Facts:

Black individuals and a branch of the National Association for the Advancement of Colored People brought actions in Federal District Court against the City of Birmingham, Alabama, and the Jefferson County Personnel Board (Board), alleging that the defendants had engaged in racially discriminatory hiring and promotion practices in violation of Title VII of the Civil Rights Act of 1964 and other federal law. Consent decrees were eventually entered that included goals for hiring blacks as firefighters and for promoting them. Respondent white firefighters subsequently brought suit in the District Court against the City and the Board, alleging that, because of their race, they were being denied promotions in favor of less qualified blacks in violation of federal law. They argued that the City and the Board were making promotion decisions on the basis of race in reliance on the consent decrees and that those decisions constituted impermissible racial discrimination. After trial, the District Court granted the defendants' motion to dismiss. It held that respondents were precluded from challenging employment decisions taken pursuant to the consent decrees, even though they had not been parties to the proceedings in which the decrees were entered. On appeal, the United States Court of Appeals reversed, rejecting the "impermissible collateral attack" doctrine that immunizes parties to a consent decree from discrimination charges by nonparties for actions taken pursuant to the decree.

Issue:

In a case alleging reverse discrimination, were the white firefighters precluded from challenging the employment decisions taken pursuant to consent decrees in previous proceedings to which the the firefighters had not been parties? 

Answer:

No.

Conclusion:

The Supreme Court of the United States affirmed the appellate judgment. According to the Court, the respondents had not been afforded an opportunity to present their arguments; thus, they should not be prevented from raising their claims based on an action to which they were not parties. The Court held that such a decision was a deprivation of respondents' rights and that they should not be deprived of their day in court.

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