Richards v. Jefferson County

In Richards v. Jefferson County (1996) 517 U.S. 793, 797, the Alabama courts had concluded that a lawsuit challenging the constitutionality of a county tax precluded a subsequent taxpayer suit raising similar claims. (Id. at pp. 795-796.) In reversing the decision, the United States Supreme Court concluded that the application of res judicata against the second group of taxpayers deprived them of due process. (Id. at p. 797.) Richards acknowledged that there are exceptions to traditional notions of privity in limited circumstances where a nonparty has had his or her interests adequately represented by someone who is a party but that the Alabama case did not meet the requirements of that exception. (Id. at p. 798.) One reason the court gave for its holding was that the parties to the first suit had not provided any notice to the parties in the second suit that their suit was pending. (Id. at p. 799.) In addition, the parties in the first suit did not purport to sue on behalf of a class or to assert any claim on behalf of any nonparties and the judgment they received did not purport to bind any other taxpayers. (Id. at p. 801.) The court concluded: "Thus, to contend that the plaintiffs in the first suit somehow represented petitioners, let alone represented them in a constitutionally adequate manner, would be 'to attribute to them a power that it cannot be said that they had assumed to exercise.' Because petitioners and the first suit's litigants are best described as mere 'strangers' to one another, we are unable to conclude that the first suit's plaintiffs provided representation sufficient to make up for the fact that petitioners neither participated in, nor had the opportunity to participate in, the first action. Accordingly, due process prevents the former from being bound by the latter's judgment." (Id. at p. 802)