Hansberry v. Lee

311 U.S. 32 (1940)

What's Going On?

Writ of certiorari to review a decision holding that a party was bound by a prior decision in which a racially restrictive covenant was upheld.

Who's Who?

Petitioners    :

Hansberry, et al – (original defendant) black family who purchased a home in an area covered by a racially restrictive covenant, and the people from whom the home was purchased.

Respondents :

Lee, et al – (original plaintiff) landowner attempting to prevent Defendants from purchasing a home because they are black.

Facts:

Petitioners, the Hansberrys, a black family, purchased a home in an area allegedly covered by a racially restrictive covenant. The covenant had been signed by 54% of the landowners in the area, but, by its terms, would only take effect if signed by 95% of the landowners. Respondent Lee, a landowner in the area, brought an action in state court to enjoin breach of the covenant against Petitioners the Hansberrys, and the people who sold the home to the Hansberrys. Petitioners argued that the covenant was not effective because it had not been signed by 95% of the owners. Respondent Lee argued that the issue of whether the covenant was effective was res judicata by a previous judgment rendered in Burke [v. Kleiman], in which the same covenant had been upheld. The judgment rendered in Burke was made following a false stipulation that 95% of the landowners had signed the covenant. In spite of the false stipulation in Burke, the trial court and state supreme court found that Petitioners were bound by its decree because Burke was a class action and Petitioners were members of the class represented in the action. The U.S. Supreme Court granted certiorari.

Issue:

May a party be bound by a judgment rendered in a previous class suit where the interests of the class in that suit were contrary to the interests of the party against whom the judgment is purported to be binding?

Decision:

No. Where the procedure adopted in a class suit does not fairly insure the protection of the interests of absent parties who are to be bound by the judgment, a court violates due process by holding that a judgment rendered in the class suit is res judicata as to members of the class who were not formal parties to the suit. In accordance with due process, the members of a class who were not present as parties to the litigation may be bound by the judgment where they are adequately represented by parties who are present. Those who seek to enforce the covenant in this case cannot be said to be in the same class with, or represent those whose interest is in resisting performance. Because of the dual and potentially conflicting interests of those who are putative parties to the agreement, it is impossible to say that either of them is in the same class. The doctrine of representation of absent parties in a class suit does not go so far as to hold that any group, merely because it belongs to a particular class, may be deemed to adequately represent any others of the class in litigating their interests in either alternative. The plaintiffs in Burke sought to compel performance of the covenant on behalf of themselves and all others similarly situated. In seeking to enforce the covenant, the plaintiffs were not representing Petitioners, whose substantial interest is in resisting performance of the covenant. Petitioners were not adequately represented by the plaintiffs in Burke, as required by due process. Reversed.

Basic Rule:

Where the procedure adopted in a class suit does not fairly insure the protection of the interests of absent parties who are to be bound by the judgment, a court violates due process by holding that a judgment rendered in the class suit is res judicata as to members of the class who were not formal parties to the suit.

Terms:

Class suit:

A suit on behalf of members of a large group of persons brought by a single person or a small group of persons who represent the larger group.

Res judicata :

Latin for “the thing has been decided.” 1. Doctrine under which a final judgment by a court of competent jurisdiction preclusive relitigation by the parties of the same issue or cause of action in a subsequent case. 2. An issue that has been decided by a court of competent jurisdiction and carries a preclusive effect.

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