Martin v. Wilks

Black firefighters sued the City of Birmingham (defendant) for racially discriminatory hiring and promotion practices, and the city settled by entering a consent decree setting hiring and promotion goals for black firefighters. A group of white firefighters (plaintiffs) later sued the city, claiming they were passed over for promotions in favor of less-qualified black firefighters because of that same consent decree. The city argued the consent decree barred the white firefighters' suit as an impermissible collateral attack, and the district court agreed and dismissed; the Eleventh Circuit reversed, holding the white firefighters — who were never parties to the original suit — could not be bound by its consent decree. The Supreme Court granted certiorari.