Richards v. Jefferson County

RESPONDENT: Jefferson County
LOCATION: Denver Area Consortium

DOCKET NO.: 95-386
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: Supreme Court of Alabama

CITATION: 517 US 793 (1996)
ARGUED: Mar 26, 1996
DECIDED: Jun 10, 1996

William J. Baxley - Argued the cause for the petitioners
William M. Slaughter - Argued the cause for the respondents

Facts of the case

Jason Richards and others, who are privately employed in Jefferson County, filed a state court class action suit claiming that the county's occupation tax violates the Federal and Alabama Constitutions. The Alabama trial court found that their state claims were barred by a prior adjudication, Bedingfield v. Jefferson County. The unsuccessful Bedingfield adjudication of the tax was brought by Birmingham's acting finance director and the city itself, consolidated with a suit by three county taxpayers. However, the court found that their federal claims had not been decided in that case. On appeal, the county argued that the federal claims were also barred. The State Supreme Court agreed, concluding that the doctrine of res judicata applied because Richard and others were adequately represented in the Bedingfield action.


May the Alabama residents, who claim that the Jefferson County occupation tax violates the Federal and Alabama Constitutions, proceed with their class action suit in court in light of a prior, similar adjudication?

Media for Richards v. Jefferson County

Audio Transcription for Oral Argument - March 26, 1996 in Richards v. Jefferson County

William H. Rehnquist:

We'll hear argument now in Number 95-386, Jason Richards v. Jefferson County.

Mr. Baxley.

William J. Baxley:

Mr. Chief Justice, may it please the Court:

This is a res judicata due process question that we're here on today.

To lead in, I'd like to give a short quote out of a case of Chase National Bank v. Norwalk.

Justice Brandeis said, unless duly summoned to appear in a legal proceeding, a person not a privy may rest assured that a judgment recovered therein will not affect his legal rights.

That quote was also cited by Mr. Chief Justice in the Martin v. Wilks case and quoted along with some other quotes from Justice Brandeis in that case.

The second little lead in quote I'd like to give... because it was cited, the case was cited by the respondent.

It's a Fifth Circuit case, Southwest Airlines v. Texas International, and they quoted Judge Widdeson as saying, quote, denial of the opportunity to bring a suit raises serious due process questions.

Further in the opinion, they quote, again, Judge Widdeson, because res judicata denies a nonparty his day in court, the Due Process Clause prevents preclusion when the relationship between the party and the nonparty becomes too attenuated.

In this instance, it's not only a attenuated relationship, there's a nonexistent relationship.

There's absolutely--

Sandra Day O'Connor:

Well, Mr. Baxley, there... your opponents cite a string of cases, many of them State cases, in which some kind of claim preclusion doctrine, or res judicata, if you will, has been applied despite a change in the identity of the plaintiff taxpayer in suits by citizens challenging tax laws in State court.

Now, there is that body of authority, and how do you deal with that, and what's the extent of it?

William J. Baxley:

--All of those cases that they cited in that footnote, only two or three of them do I think really have application that they should have to be arguable.

All of them are State cases.

I believe all of them are State cases.

I don't believe there's a single case from this Court or even a circuit court that they cited in that footnote.

I think common sense is the best answer.

These are cases that I think that the law, especially when you're dealing with a constitutional right to have your case litigated--

Sandra Day O'Connor:

Well, you take the position that there is no doctrine of claim preclusion in these citizen taxpayer suits in State court?

William J. Baxley:

--I think the position that we would take is... was enunciated in your dissent, in Justice O'Connor's dissent in the Harper v. Virginia case which is--

Sandra Day O'Connor:

But remember, that was a dissent.

William J. Baxley:

--But it did not conflict with the majority, either--

Sandra Day O'Connor:

It didn't carry the day.

William J. Baxley:

--and you quoted United States v. L.A. Tucker Trucking Company and Webster v. Fall, and I think your quote there was something to the effect that questions which are merely lurk in the record have no basis of precedent in--

Sandra Day O'Connor:

Well, what if the court in the Bedingfield case here had actually decided the issue that you're raising now, would you be here?

William J. Baxley:

--It would be a closer question.

I think that--

Sandra Day O'Connor:

And what is your answer?