Hansberry v. Lee case brief
Posture: Suit brought in Illinois state court to enforce a racially restrictive covenant involving land in Chicago. A black man purchased the land from an owner who signed the covenant so suit was being brought to enjoin the sale as a breach. Plaintiff further alleges that the covenant was binding as of a previous court. Defendants plead that they are not bound by res judicata because they were not parties in previous suit. Illinois State court found res judicata, Supreme Ct of Illinois affirmed and SCOTUS reverses.
Facts: Covenant provided that it was not effective unless 95% of the landowners signed it, which they had 95% of landowners sign. Plus claimed res judicata off of a previous claim that only had 54% of owners sign, and even though they thought it was rested on a false and fraudulent stipulation of the parties. Defendant argued that it would be a denial of due process to hold them to first degree since they were not a party to agreement. Supreme found that although stipulation was untrue, it was not fraud. Found that the 1st suit was a representative suit and was binding on all class members and that Hansberry was a member of class being represented.
Reasoning: There is a principle that one is not bound by a judgment in personam if they were not designated as a party. Representative suits are the exception, because it must bind all such class members. As long as the interests joined and not joined are of same class AND fairly represents the non-joined parties in the litigation, court will proceed to honor a decree.
There is a failure of due process only where it cannot be said that the procedure fairly insures the protection of the interests of absent parties who are to be bound by it. Basically procedure must protect the due process of people who are absent and when it does it satisfies requirements of due process and full faith and credit.
Only decide that in this case, requirements are not satisfied. They decide this because it only binds those people who signed the argument and not everyone else. The class of people are completely different in future years, and they can still challenge the validity of this agreement. It is weird to say that everyone who is free to assert a right or challenge them are of the same class. They are not representative of each other, both are different parties and classes.
Here, plaintiffs cannot be trying to bind defendants because defendants are ones trying to resist such binding! That is most important issue here.