Martin v. Wilks case brief

Martin v. Wilks case brief

1989 SCOTUS

Posture: District Court held that the consent decrees were a defense while the court of appeals reversed on the count that white firefighters were not a party so they could not be precluded. SCOTUS affirmed the reversal. 

Facts: City of Birmingham and Jefferson County Board had consent judgments with black firefighters setting hiring goals and promotion goals. White firefighters who were not a party, sued the city and board alleging denial of promotions on race. City and board defended on consent decrees, which asked for these challenged promoting practices and tried to use it in the current suit.  

Reasoning: Defendant’s say that because firefighters waited to bring suit, they should be barred because now its just a collateral attack. SCOTUS disagreed. A party seeking a binding judgment cannot obligate a person to intervene, they must join them. Joinder instead of knowledge is the method by which a potential party is subjected to the jurisdiction of the court and bound by a judgment. It makes sense to put the burden of bringing on additional parties to the person seeking a judgment where such a step is needed rather than having the other party intervene in a lawsuit they are interested in.
**Parties who choose to resolve litigation through a settlement may not dispose of the claims of a third party without that party’s agreement. If a party is nonconsenting to that settlement then it cannot be binding under any circumstances. 

Stevens Dissent: Thinks that because the firefighters had notice and a reasonable opportunity to intervene, that their time to bring a suit had passed. 

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