Los Angeles Branch Naacp v. Los Angeles Unified School District

Court of Appeals for the Ninth Circuit
750 F.2d 731 (1985)

ELI5:

Rule of Law:

The doctrine of res judicata (claim preclusion) bars a subsequent lawsuit concerning the same primary right, but its preclusive effect only extends to claims that arose up to the close of the trial on the merits in the prior action, not to new claims arising from conduct that occurred after the trial concluded.

Facts:

In 1963, a class action, Crawford v. Board of Education, was filed in California state court on behalf of black and Hispanic students against the Los Angeles Unified School District (the District), alleging school segregation.
The Crawford lawsuit was based on the California Constitution's requirement for school boards to alleviate racial segregation, regardless of whether it was de facto (unintentional) or de jure (intentional).
During the Crawford trial, which concluded on May 2, 1969, the plaintiffs presented evidence and the court made findings related to the District's intentional segregative acts.
In 1979, California voters passed Proposition I, which amended the state constitution to limit state courts' power to order busing remedies to only those situations where a federal court could—i.e., to remedy intentional (de jure) segregation that violates the U.S. Constitution.
Following the passage of Proposition I, the state appellate court in the Crawford case re-evaluated the basis for the existing desegregation plan.
The state appellate court ultimately concluded that the findings from the original 1969 trial did not support a conclusion of de jure segregation under then-current federal standards.
Based on this conclusion, the state court approved a new desegregation plan for the District that did not include mandatory busing or pupil reassignment, and the litigation concluded.

Procedural Posture:

The NAACP filed a class action lawsuit in the U.S. District Court for the Central District of California against the Los Angeles Unified School District, alleging intentional (de jure) segregation.
The District moved for summary judgment, arguing the lawsuit was barred by the doctrine of res judicata due to a prior state court case, Crawford v. Board of Education.
The U.S. District Court, as the trial court, denied the District's motion for summary judgment.
The District Court certified its order for an interlocutory appeal to the U.S. Court of Appeals for the Ninth Circuit.
A three-judge panel of the Ninth Circuit initially reversed the district court, holding the claim was barred.
The Ninth Circuit subsequently granted a petition for rehearing en banc, withdrew the panel's opinion, and heard the appeal.

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Issue:

Does the doctrine of res judicata, based on a prior state court desegregation lawsuit (Crawford), bar a subsequent federal lawsuit alleging de jure segregation by the same school district for actions taken both before and after the conclusion of the first trial?

Opinions:

Majority - Canby, Circuit Judge

Partially. Res judicata bars the new federal lawsuit, but only as to the District's alleged segregative acts that occurred on or before May 2, 1969, the date the trial on the merits in the Crawford case concluded. The court reasoned that under California's 'primary rights' theory, both the state and federal lawsuits sought to vindicate the same primary right: the right to an equal opportunity for education. However, claim preclusion does not apply to new rights or claims arising after the original litigation was framed. The scope of the Crawford litigation was fixed by the pleadings and a stipulation to cover events only up to the end of the trial on the merits in 1969. All subsequent proceedings in state court concerned the remedy for those pre-1969 acts, not liability for new acts occurring after 1969. Therefore, any claim based on segregative acts committed by the District after May 2, 1969, constitutes a new cause of action that is not barred.

Concurring-in-part-and-dissenting-in-part - Sneed, Circuit Judge

Yes. Res judicata should bar the entire claim, including any alleged segregative acts that occurred up to the entry of the final state court order in 1981. The majority's 1969 cut-off is overly formalistic. The passage of Proposition I put the entire issue of de jure segregation back on the table, and the school board's subsequent application for modification of the desegregation plan acted as a supplemental pleading that put all facts 'which exist at the time of such modification' at issue. The Crawford plaintiffs had the opportunity and incentive to prove de jure segregation based on any acts up to 1981 to justify a busing remedy; by failing to do so, they are precluded from raising those claims in a new lawsuit.

Concurrence - Pregerson, Circuit Judge

Yes, but only for pre-1969 acts. The majority's opinion correctly opens the federal courthouse doors for plaintiffs to prove that the school district engaged in intentional discrimination after May 2, 1969. It is important to note that this decision does not prevent the plaintiffs from introducing evidence of the district's pre-1969 acts for the limited purpose of shedding light on the district's intent in its post-1969 actions.

Concurring-in-part-and-dissenting-in-part - Poole, Circuit Judge

No. Res judicata should not bar the pre-1969 claims because the plaintiffs never had a 'full and fair opportunity' to relitigate them after the state appellate court's decision in Crawford II. While the majority correctly holds that post-1969 claims are not barred, it is wrong to conclude that the plaintiffs had a realistic chance to reopen the pre-1969 de jure issue. The Crawford II court's heavy-handed reversal of the trial court's factual findings and its restrictive mandate created a time-constrained and procedurally difficult environment that effectively foreclosed any meaningful relitigation of the original claim.

Analysis:

This decision establishes a significant precedent on the temporal scope of claim preclusion in institutional reform litigation where wrongful conduct may be ongoing. By tying the preclusive effect to the close of the liability trial rather than the final judgment, the court balances finality with fairness. It prevents plaintiffs from relitigating a specific historical period already decided but preserves their ability to challenge new, subsequent violations in a separate action. This avoids forcing plaintiffs into a potentially unworkable requirement of continuously filing supplemental pleadings for every new act that occurs during protracted remedial phases of litigation.

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