Richards v. Jefferson County

Brief Fact Summary.

When two taxpayers sought to challenge a tax imposed by Jefferson County, Alabama, the Alabama Supreme Court concluded that all of the claims were precluded due to a previous lawsuit commenced by the City of Birmingham and its finance director.

Synopsis of Rule of Law.

Under the doctrine of res judicata, plaintiffs cannot be bound to a judgment in an earlier suit if the plaintiffs were not parties to the original suit, given notice to participate in the suit, and were represented by existing parties.

Facts.

The City of Birmingham and its finance director sued to challenge an occupation tax imposed by Jefferson County, Alabama. When the Alabama Supreme Court upheld the tax, two taxpayers, Richards and Hill, subsequently sued to challenge the tax. The suit was dismissed and summary judgment was granted to the county on the state law claims. When the county appealed, the Alabama Supreme Court concluded that all of the claims were precluded because of the previous lawsuit.

Issue.

Whether plaintiffs can be bound to a judgment in an earlier suit if the plaintiffs were not parties to the original suit, give notice to participate in the suit, and were represented by existing parties?

Held.

No. Res judicata is unconstitutional because the subsequent plaintiffs were strangers to the suit, did not have notice to participate in the suit, and therefore cannot be bound by the suit.

Discussion.

Parties to a suit may not relitigate a claim that was already decided by a claim. This rule only applies to the same parties in the original suit. Individuals are not bound to a judgment if they are not the original parties to a suit.