Facts of the Case

As a result of a lawsuit in 1974, the Jefferson County Personnel Board in Birmingham, Alabama, entered into consent decrees that included hiring blacks as firefighters and for promoting them. The decrees were approved by a federal district court. Years later, Robert K. Wilks, a white firefighter, challenged the decrees and alleged that whites were being denied promotions in favor of less qualified blacks. Wilks argued that such practices violated Title 7 of the Civil Rights Act of 1964. The personnel board agreed that it was making race-conscious decisions but argued it was doing so pursuant to the original decrees. The Court combined arguments in two companion cases: Personnel Board v. Wilks and Arrington v. Wilks.

Question

Did Wilks and other white firefighters have a constitutional right to challenge the previously established decrees?

Conclusion

Yes. In a 5-to-4 decision, the Court held that because "a person cannot be deprived of his legal rights in a proceeding to which he is not a party," the white firefighters were not precluded from challenging employment decisions taken pursuant to the consent decrees. The Court argued that "[t]he parties to a lawsuit presumably know better than anyone else the nature and scope of relief sought in the action" and that they were better suited to intervene when their rights were immediately threatened. Conversely, the Court noted that "[n]o one can seriously contend that an employer might successfully defend against a Title VII claim by one group of employees on the ground that its actions were required by an earlier decree entered in a suit brought against it by another, if the later group did not have adequate notice or knowledge of the earlier suit."