Cooper v. Federal Reserve Bank of Richmond
United States Supreme Court
467 U.S. 867 (1984)
A certified class of Black Federal Reserve Bank employees (including Baxter and others, plaintiffs) sued for a pattern of racial discrimination; the district court found some pattern-and-practice discrimination existed but not enough to warrant classwide relief, and while that ruling was on appeal, Baxter and others filed separate individual discrimination suits, which the Bank moved to dismiss. The Fourth Circuit reversed the class judgment on the merits and separately held res judicata barred the individual Baxter suits.
Whether a judgment in a class action determining that an employer did not engage in a general pattern of racial discrimination against the certified class of employees precludes a class member from maintaining a subsequent civil action alleging an individual claim of racial discrimination against the employer.