Sunday, November 24, 2013

Martin v. Wilks case brief

Martin v. Wilks case brief summary
490 U.S. 755 (1989)

Petitioners, African-Americans, sought review of a decision of the United States Court of Appeals for the Eleventh Circuit, which reversed a trial court judgment that granted their motion to dismiss respondent Caucasian firefighters' reverse discrimination claims against a city because the challenged employment decisions were made pursuant to consent decrees in another suit.

Respondents were Caucasian firefighters who sued the city of Birmingham, Alabama, and alleged that they were discriminated against when they were passed over for promotions in favor of less qualified African-American firefighters. The trial court dismissed their claims based on prior adjudications on the same subject. While the other case was on appeal, respondents attempted to intervene, but the appellate court denied their motion. The appellate court reversed the dismissal of respondents' district court case.


  • On certiorari review, the court affirmed the judgment. 
  • The court stated that respondents had not been afforded an opportunity to present their arguments and that they should not be prevented from raising their claims based on an action to which they were not parties. 
  • The court held that such a decision was a deprivation of respondents' rights and that they should not be deprived of their day in court.
The court affirmed the appellate court's decision reversing the dismissal of respondent Caucasian firefighters' reverse discrimination case on res judicata grounds because respondents were not parties to the prior case in which the consent decrees had been entered, and they had not had an opportunity to present their case.

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