Martin v. Wilks

Brief Fact Summary. Litigation giving rise to this lawsuit began in 1974 when the NAACP and seven individuals filed separate class action lawsuits against the City of Birmingham and the city’s hiring board, alleging violations of Title VII of the Civil Rights Act of 1964 (the Act). The parties entered into consent decrees, setting forth an extensive remedial scheme, including long-term and interim annual goals for the hiring and promotion of blacks as firefighters. A group of white firefighters then brought suit against the city and the board in district court for making race conscious employment decisions.
Synopsis of Rule of Law. A person cannot be bound by a judgment to which he was not a party, even thought the person was aware of the prior litigation and failed to file a motion to intervene.

Facts. Litigation giving rise to this lawsuit began in 1974 when the NAACP and seven individuals filed separate class action lawsuits against the City of Birmingham and the city’s hiring board, alleging violations of the Act. The parties entered into consent decrees, setting forth an extensive remedial scheme, including long-term and interim annual goals for the hiring and promotion of blacks as firefighters. Before final approval of the decrees, the Birmingham Firefighters Association (BFA) appeared and filed objections as amicus curiae. The BFA also moved to intervene on the ground that the decrees would adversely affect their rights. The district court denied relief. The Wilks Respondents, a new group of white firefighters (Respondents), in the present case then brought suit against the city and the board in district court for making race conscious employment decisions. The Martin Petitioners, a group of black individuals (Petitioners), were allowed to intervene in their individual capacities to defend the decrees. Petitioners moved to dismiss the reverse discrimination cases as impermissible collateral attacks on the consent decrees. The district court granted the motion to dismiss. On appeal, the Court of Appeals for the Eleventh Circuit reversed. The Supreme Court of the United States (Supreme Court) granted certiorari.

Issue. Whether a person can be bound by a judgment, through collateral estoppel, of a prior consent decree to which he was not a party, where the person was aware of the prior litigation and failed to file a motion to intervene.

Held. No. The Supreme Court affirmed the Eleventh Circuit’s judgment. One is not bound by a judgment in personam in which he is not designated as a party or to which he has not been made a party by service of process. A judgment or decree among parties to a lawsuit resolves issues among them, but it does not conclude the rights of strangers to those proceedings. A party seeking a judgment binding on another cannot obligate that person to intervene. He must be joined. Joinder as a party, rather than knowledge of a lawsuit and an opportunity to intervene, is the method by which potential parties are subjected to the jurisdiction of the court and bound by a judgment or decree.

Dissent. Justice John Paul Stevens (J. Stevens) dissented, in which he was joined by Justices William J. Brennan (J. Brennan), Thurgood Marshall (J. Marshall), and Harry A. Blackmun (J. Blackmun). The dissent distinguished between persons who are actual parties to litigation and persons who merely have the kind of interest that may as a practical matter be impaired by the outcome of a case. Persons in the latter category, these Justices held, have a right to intervene, or may be joined. If they elect to stay on the sidelines, they may be harmed as a practical matter even though their legal rights are unaffected. Under their view, such a bystander has not right to appeal from the judgment.

Discussion. This case can be read as answering the question of who has the responsibility to ensure that all vital interests are represented in a lawsuit. The view proposed by the dissent is that the absentees must intervene under Federal Rule of Procedure (FRCP) Rule 24 or suffer any unfavorable result. Instead, the majority held that the actual parties to the suit are required to join any parties they wish the judgment of the suit to have control over, or face subsequent litigation.