Martin v. Wilks

A group of Black firefighters filed a class-action lawsuit against the City of Birmingham and the Jefferson County Personnel Board (collectively, the city) (defendants). The Black firefighters alleged that the city had engaged in racially discriminatory employment practices. To settle the lawsuit, the city entered into a consent decree, which set requirements for hiring and promoting Black firefighters. Some White firefighters tried to intervene in the lawsuit, but their request was untimely. The court entered the consent decree as a judgment in this first lawsuit. Robert Wilks and a group of White firefighters (plaintiffs) filed a second lawsuit against the city, arguing that the consent-decree judgment was racially discriminatory and had caused them to be denied promotions in favor of less qualified Black firefighters. The district court dismissed the second lawsuit. The court found that the White firefighters (1) had not been passed over for less qualified Black firefighters and (2) could not collaterally attack the first lawsuit’s judgment—meaning contest the legality of that judgment—in a new proceeding. If the White firefighters had wanted to contest that judgment, the court reasoned, they should have properly intervened in the first lawsuit. The Eleventh Circuit court of appeals reversed, holding that the first lawsuit’s judgment could not preclude the White firefighters’ claims because the White firefighters had not been parties to that prior action. The United States Supreme Court granted certiorari.