Gonzales v. Cassidy case brief

Gonzales v. Cassidy case brief summary
474 F.2d 67 (1973)

CASE SYNOPSIS

Appeal from the decision of the United States District Court for the Northern District of Texas, which determined that res judicata foreclosed appellant's claims in a class action suit.

CASE FACTS
Appellant brought a class action suit, challenging the constitutionality of the Texas Safety Responsibility Act (TSRA), Tex. Rev. Civ. Stat. Ann., art. 6701h (1969). A prior class suit represented by a different named plaintiff involving the same class, the same defendants, and the same issues, was successful in obtaining a declaration that TSRA was unconstitutional. The decision was applied retroactively to named plaintiff, but retroactive relief to other members of the class was denied. Named plaintiff failed to appeal the determination denying retroactive relief to the other members of the class.

DISCUSSION

• The court determined that the principles of res judicata could not be applied to bind appellant. Although named plaintiff was an adequate representative of the class at the time his suit was initiated, under Fed. R. Civ. P. 23(a)(4), the failure of named plaintiff to appeal the decision denying retroactive relief to other members of class rendered his representation inadequate.

CONCLUSION
The judgment applying the principles of res judicata to bind appellant to a prior suit was reversed, because the named plaintiff in the prior class action suit failed to appeal the decision to deny retroactive relief to other members of the class. The court remanded to the district court to resolve two issues: (1) whether the action may be maintained as a class action, and (2) the issue of retroactivity.


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