Martin v. Wilks
Encyclopedia
Martin v. Wilks, 490 U.S. 755
(1989), was a U.S. Supreme Court
case brought by Robert K. Wilks challenging the validity of race-based hiring practices.
In 1974, the Jefferson County, Alabama
Personnel Board signed a consent decree that required them to hire and promote African-American firefighters. Wilks, a white fireman, took issue with the agreement, claiming that he and other white firefighters (who were not parties to the original consent decrees signed in 1974) were more qualified than some of the black firefighters receiving promotions. The Supreme Court of the United States
upheld the appeal of the white firefighters in a 5-4 decision on the issue of whether the white firefighters have a constitutional right to challenge the previously established decrees.
Chief Justice William Rehnquist
wrote for the majority. They reasoned that a person cannot be denied his rights in a proceeding to which he was not a party. Since the white firefighters did not have valid notice of the original proceeding, they should have their appeal sustained and the decrees overturned.
Justice John Paul Stevens
wrote the dissent
, and he was joined by Justice William Brennan
, Justice Thurgood Marshall
, and Justice Harry Blackmun
. The dissent reasoned that the white firefighters should have had only limited means to appeal given that they were challenging the validity of the consent decrees but were not original parties to the consent decrees and that the majority overstepped the authority of the court.
It is noteworthy that despite the racial overtones of the case and the sensitive public issues of civil rights
and affirmative action
, the core dispute of the case is one regarding proper procedure. The Court argued that the white firefighters should have been joined
as parties to the original proceeding under the Federal Rules of Civil Procedure
Rule 19(a).
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1989), was a U.S. Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case brought by Robert K. Wilks challenging the validity of race-based hiring practices.
In 1974, the Jefferson County, Alabama
Jefferson County, Alabama
Jefferson County is the most populous county in the U.S. state of Alabama, with its county seat being located in Birmingham.As of the 2010 U.S. Census, the population of Jefferson County was 658,466...
Personnel Board signed a consent decree that required them to hire and promote African-American firefighters. Wilks, a white fireman, took issue with the agreement, claiming that he and other white firefighters (who were not parties to the original consent decrees signed in 1974) were more qualified than some of the black firefighters receiving promotions. The Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
upheld the appeal of the white firefighters in a 5-4 decision on the issue of whether the white firefighters have a constitutional right to challenge the previously established decrees.
Chief Justice William Rehnquist
William Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
wrote for the majority. They reasoned that a person cannot be denied his rights in a proceeding to which he was not a party. Since the white firefighters did not have valid notice of the original proceeding, they should have their appeal sustained and the decrees overturned.
Justice John Paul Stevens
John Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
wrote the dissent
Dissenting opinion
A dissenting opinion is an opinion in a legal case written by one or more judges expressing disagreement with the majority opinion of the court which gives rise to its judgment....
, and he was joined by Justice William Brennan
William J. Brennan, Jr.
William Joseph Brennan, Jr. was an American jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990...
, Justice Thurgood Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
, and Justice Harry Blackmun
Harry Blackmun
Harold Andrew Blackmun was an Associate Justice of the Supreme Court of the United States from 1970 until 1994. He is best known as the author of Roe v. Wade.- Early years and professional career :...
. The dissent reasoned that the white firefighters should have had only limited means to appeal given that they were challenging the validity of the consent decrees but were not original parties to the consent decrees and that the majority overstepped the authority of the court.
It is noteworthy that despite the racial overtones of the case and the sensitive public issues of civil rights
Civil rights
Civil and political rights are a class of rights that protect individuals' freedom from unwarranted infringement by governments and private organizations, and ensure one's ability to participate in the civil and political life of the state without discrimination or repression.Civil rights include...
and affirmative action
Affirmative action
Affirmative action refers to policies that take factors including "race, color, religion, gender, sexual orientation or national origin" into consideration in order to benefit an underrepresented group, usually as a means to counter the effects of a history of discrimination.-Origins:The term...
, the core dispute of the case is one regarding proper procedure. The Court argued that the white firefighters should have been joined
Joinder
Joinder is a legal term, which refers to the process of joining two or more legal issues together to be heard in one hearing or trial. It is done when the issues or parties involved overlap sufficiently to make the process more efficient or more fair...
as parties to the original proceeding under the Federal Rules of Civil Procedure
Federal Rules of Civil Procedure
The Federal Rules of Civil Procedure govern civil procedure in United States district courts. The FRCP are promulgated by the United States Supreme Court pursuant to the Rules Enabling Act, and then the United States Congress has 7 months to veto the rules promulgated or they become part of the...
Rule 19(a).
See also
- List of United States Supreme Court cases, volume 490
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court
- Hansberry v. LeeHansberry v. LeeHansberry v. Lee, , is a famous case now usually known in civil procedure for teaching that res judicata may not bind a subsequent plaintiff who had no opportunity to be represented in the earlier civil action. The facts of the case dealt with a racially restrictive covenant that barred African...
,