Brief Fact Summary.
Birmingham attempts to use a consent decree from a case with Black firefighters to bind a subsequent case brought by white firefighters.
Synopsis of Rule of Law.
A judgement is only binding on the parties to a lawsuit and has no impact on the rights of a nonparty who was not joined even if they had the opportunity to do so.
Consent decrees have attributes both of contracts and of judicial decrees; a dual character that has resulted in different treatment for different purposes.View Full Point of Law
A group of black firefighters sued the City of Birmingham and the Jefferson County Personnel Board for race dsicrimination. To settle the suit, Birmingham entered a consent decree that set requirements for hiring and promoting black firefighters. Subsequently, a group of white firefighters sued Birmingham and the Board alleging that they were being denied promotions because the consent decree allowed less qualified black firefighters to be promoted instead. Birmingham alleged that the consent decree precluded the white firefighters’ lawsuit and therefore moved to dismiss their lawsuit arguing that it was impervious to collateral attack. The district court granted the motion but the Eleventh Circuit Court of Appeals reversed, holding that Plaintiffs’ claims would not be precluded because they were not parties to the consent decree action. The Supreme Court of the United States granted certiorari.
Will a nonparty who failed to voluntarily intervene in an earlier action be barred from bringing a related claim in a subsequent lawsuit?
No, a nonparty who failed to voluntarily intervene in an earlier action may not be barred from bringing a related claim in a subsequent lawsuit. Decision of the court of appeals is affirmed.