Richards v. Jefferson County
Supreme Court
517 U.S. 793 (1996)
After Alabama's highest court upheld Jefferson County's occupation tax in a suit brought by the City of Birmingham and three individual taxpayers (Bedingfield), Jason Richards and Fannie Hill (plaintiffs) later sued on behalf of a class of all county taxpayers, challenging the same tax on federal and state constitutional grounds. Their federal suit was dismissed under the Tax Injunction Act, and in state court, the trial court found their state-law claims barred by the earlier Bedingfield decision; the Alabama Supreme Court went further, holding all their claims -- including the federal ones -- were precluded because the Bedingfield taxpayers had adequately represented them.
Whether, under the doctrine of res judicata, plaintiffs may be bound by a judgment in an earlier action if they were not parties to that suit, were not given notice and an opportunity to be heard, or were not adequately represented by the existing parties.