Hansberry v. Lee (S.Ct. 1940)
Facts:
Hansberry, a black man, purchased land that may have been subject to a racially restrictive covenant. Lee, an owner of land subject to the same covenant, sought to enforce the restriction. According to the covenant, the restriction would only be valid if signed by 95 percent of the landowners. In a prior case, to which neither Hansberry nor any other minorities were a party, a state judge had held that 95 percent of the landowners had signed.
Issue:
Can an individual be bound by a prior action in which he was not a party based on the fact that both he and the party in the previous suit are members of the same class?
Rule:
(Stone, J.) Due process requires that members of a class not present as parties to an action be bound by the judgment only if they were adequately represented by the parties present. Such members are also bound if they participate in the litigation, if they have joint interests, or if a legal relationship exists between the parties present and those absent such as to entitle the former to stand in judgment for the latter. None of these criteria was present in this case.
