Hansberry v. Lee

Brief Fact Summary. The Hansberrys (Defendants), a black family, bought a house in an area of Chicago allegedly covered by a racially restrictive covenant. Lee (Plaintiff) brought an action in Illinois state court to enjoin breach of the covenant, naming as defendants both the Defendant’s, and the people from whom the Defendant’s had bought the property. Plaintiff sought the use of an earlier class action judgment regarding the covenant to prevent the Hansberry’s from litigating the issue of whether the covenant was valid.

Synopsis of Rule of Law. A judgment rendered in a class suit is res judicata as to members of the class who are not formal parties to the suit; however, a selection of representatives for purposes of litigation, whose substantial interests are not necessarily or even probably the same as those whom they are deemed to represent does not afford that protection to absent parties which due process requires.

Facts. Defendants, a black family, bought a house in an area of Chicago allegedly covered by a racially restrictive covenant. Plaintiff brought an action in Illinois state court to enjoin breach of the covenant, naming as defendants both the Defendant’s, and the people from whom the Defendant’s had bought the property.
Plaintiff referred the court to an earlier suit to enforce the same covenant. In that case a property owner had sued four individuals in violation of the covenant, and the Illinois court upheld the covenant. The Supreme Court of Illinois in this case determined that the earlier case had been a class action, that Defendants were members of the class of plaintiffs in the earlier case, and that there were therefore bound by the findings in the previous action.
It is one thing to say that some members of a class may represent other members in a litigation where the sole and common interest of the class in the litigation, is either to assert a common right or to challenge an asserted obligation. It is quite another to hold that all those who are free alternatively to either assert rights or to challenge them are of a single class, so that any group, merely because it is of the class so constituted, may be deemed adequately to represent any others of the class in litigating their interests in either alternative.

Issue. Whether a state court has deprived Petitioners of the due process of law guaranteed by the Fourteenth Amendment by its adjudication that Petitioners are bound by an earlier judgment to which they were not parties.

Held. Yes. The Supreme Court of the United States reversed the decision of the Illinois Supreme Court.
When the judgment of a state court, applying res judicata effect to the judgment of an earlier court, is challenged on due process grounds it becomes the duty of the reviewing court to examine the course of procedure in both litigations to ascertain whether the litigants have been afforded the notice and opportunity to be heard that are required under the Due Process Clause.

The judgment in a class action, to which some members of the class are parties, may bind members of the class or those represented who were not made parties to it. A judgment rendered in a class suit is res judicata as to members of the class who are not formal parties to the suit.

Discussion. In assessing any complaint involving due process, the inquiry necessarily deals with notice and opportunity to be heard. One way of looking at this case is to say that one must have been a member of the class of plaintiffs at the time the original litigation was been filed in order to receive substantial notice and the opportunity to have been heard at the time the original judgment was issued.