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.
Respondents were Caucasian firefighters who sued the city of Birmingham, Alabama, and alleged that they were discriminated against when they were passed over for promotions in favor of less qualified African-American firefighters. The trial court dismissed their claims based on prior adjudications on the same subject to which respondents were not parties. While the other case was on appeal, respondents attempted to intervene, but their motion was denied. The appellate court reversed the dismissal of respondents' district court case. On certiorari review, the court affirmed the judgment.
Were respondents, who were not parties to prior civil rights litigation, precluded from challenging, the consent decrees?
The court stated that respondents had not been afforded an opportunity to present their arguments and that 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.