Hansberry v. Lee

Brief Fact Summary.

White homeowners attempting to keep Black people from acquiring land subject to a racially restrictive covenant try to use a prior ruling—in which the Black homeowners were not parties—to bind them.

Synopsis of Rule of Law.

Under the Due Process Clause of the Fourteenth Amendment, res judicata may only be used against parties that were adequately represented in the prior action.

Facts.

A group of white landowners in Chicago signed a restrictive covenant to keep Black people from living on the land. To be effective, 95% of owners would need to sign it, but only about 54% did. However, in an earlier class action suit, regarding the covenant, Burke, it was stated that 95% of the owners had signed. Plaintiff Lee on behalf of herself and others brought suit against Defendant Hansberry and other Black people to enjoin them from breach of covenant because they acquired land with knowledge of the restrictive covenant. The Plaintiffs argued that the percentage of owners that had signed was already determined in Burke and should be given res judicata effect. Defendant argued res judicata should not apply because they were not parties to Burke and that to allow res judicata would violate their Fourteenth Amendment right to due process. The trial court ruled that Defendants were bound by Burke and the Supreme court of Illinois affirmed. Defendants petitioned the Supreme Court of the United States for certiorari.

Issue.

May a party not party to a prior court ruling be constitutionally bound by that prior ruling if their interests were not adequately represented in the previous action?

Held.

No, a party that was not party to a prior court ruling may not be constitutionally bound by that prior ruling if their interests were not adequately represented in the previous action. Decision of the lower court is reversed.

Concurrence.

Justice Justices McReynolds, Roberts, and Justice Reed concurred in the result

Justices McReynolds, Roberts, and Justice Reed concurred in the result

Discussion.

1. State courts are usually free to determine who will be bound by prior court rulings, limited by Constitutionality.
2. But it is the responsibility of the court to determine whether a party’s rights have been fairly adjudicated and the person given proper due process.
3. A party is not generally bound by a prior decision unless they were served or named in the litigation.
The exception to this is when a person qualifies as a class member even though they were not made a party to that class.
4. While there are no rules governing how states bind nonparties to prior class action, the interests of the nonparties must be adequately protected.
5. Therefore, a nonparty to a prior class action will only be bound if they were adequately represented, actually participated, had joint interest, or had a legal relationship with one of the present parties in the prior action.
6. The plaintiffs in Burke have diverging interests from the Defendants in this case: the former wanted to enforce the restrictive covenant while the Defendants here seek to resist it.
7.Therefore the Defendants cannot be said to have been a part of the class in the Burke action and therefore cannot be bound by the Burke decision without violating the due process.