Hansberry v. Lee
311 U.S. 32 (1940)
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Rule of Law:
The Due Process Clause of the Fourteenth Amendment prohibits binding a litigant to a judgment in a prior class action suit in which they were not a party and where their interests were not adequately represented by the parties who were present.
Facts:
- A number of landowners in a Chicago neighborhood created a restrictive covenant agreement.
- The agreement stipulated that no part of the land could be sold to, leased to, or occupied by any Black person for a specified period.
- A condition of the agreement was that it would not become effective unless it was signed by the owners of 95% of the property frontage in the designated area.
- In reality, only about 54% of the eligible property owners had signed the agreement, meaning the condition for its effectiveness was never met.
- Carl Hansberry, a Black man, later purchased and moved into a home within the area covered by the agreement.
- The property purchased by Hansberry was from an owner who had signed the covenant.
Procedural Posture:
- In a prior lawsuit, Burke v. Kleiman, a landowner sued in an Illinois state court to enforce the restrictive covenant, claiming to represent all similar landowners.
- In the Burke case, the parties falsely stipulated that the 95% signature requirement had been met, and the court entered a decree enforcing the agreement.
- Years later, respondents (including Lee) sued petitioners (including Hansberry) in the Circuit Court of Cook County, Illinois, seeking an injunction to enforce the covenant against them.
- Petitioners defended by arguing the covenant was invalid because the 95% signature requirement was never actually met.
- Respondents countered that the validity of the covenant was res judicata (already decided) because of the decree in Burke v. Kleiman.
- The Illinois Circuit Court found that only 54% of owners had signed but ruled that the issue was res judicata and entered a decree for the respondents.
- The Supreme Court of Illinois affirmed, holding that Burke was a class suit that bound all members of the class, including the petitioners.
- The United States Supreme Court granted certiorari to review the constitutional question.
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Issue:
Does applying the doctrine of res judicata to bind petitioners to a prior class action judgment violate the Due Process Clause of the Fourteenth Amendment when the petitioners' interests were not adequately represented by, and were in fact adverse to, the interests of the parties in the prior suit?
Opinions:
Majority - Justice Stone
Yes. Applying res judicata to bind the petitioners to the prior judgment violates the Due Process Clause of the Fourteenth Amendment. While there is a recognized exception for class or representative suits to the general rule that one is not bound by a judgment in a case to which they were not a party, this exception is subject to constitutional limitations. Due process requires that for absent parties to be bound by a class action judgment, the procedure must fairly ensure the protection of their interests. Here, the supposed 'class' of landowners had conflicting interests; some, like the plaintiffs in the prior suit, sought to enforce the covenant, while others, like the petitioners, had an interest in resisting its enforcement. Because the plaintiffs in the prior action seeking to enforce the agreement did not, and could not, adequately represent the interests of those who wished to challenge its validity, binding the petitioners to that judgment would deny them their day in court and thus violates due process.
Analysis:
This landmark decision establishes a crucial constitutional limit on the preclusive effect of class action judgments. It solidifies the principle that due process requires adequate representation for absent class members, meaning the named representatives' interests must be aligned with those of the class. The case clarifies that a 'class' cannot be composed of members with fundamentally conflicting goals regarding the litigation's subject matter. This ruling heavily influenced the development of modern class action rules, such as Federal Rule of Civil Procedure 23, which now explicitly require courts to scrutinize the adequacy of representation, commonality, and typicality before certifying a class.
