Civil Procedure
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A group of black firefighters filed a class action lawsuit against the City of Birmingham and the Jefferson County Personnel Board (the City) (defendants). The black firefighters alleged that the City had engaged in racially discriminatory hiring and promotion practices in public service jobs in violation of the Civil Rights Act of 1964. The City entered into a consent decree, which set requirements for hiring and promoting black firefighters, to settle the suit. A group of white firefighters (plaintiffs) then sued the City, arguing that they were denied promotions in favor of less qualified black firefighters because of the racially discriminatory consent decree. The City asserted that the consent decree precluded the plaintiffs’ lawsuit. Thus, the City moved to dismiss the reverse discrimination suit, arguing it was an impermissible collateral attack. The district court granted the motion. The Eleventh Circuit Court of Appeals reversed, holding that the plaintiffs’ claims could not be precluded by the consent decrees because they were not parties to the previous action. The United States Supreme Court granted certiorari.
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