Hansberry v. Lee

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Hansberry v. Lee (1940) – a short, easy-to-understand version

What the case was about
- A U.S. Supreme Court decision about due process in class actions and whether a large group judgment can bind a person whose interests weren’t properly represented.

The background
- In Chicago’s Woodlawn neighborhood, a racially restrictive covenant barred African Americans from buying or renting in the Washington Park subdivision.
- Burke v. Kleiman was a prior class action that included all homeowners who signed the covenant or whose owners signed. The court in that case said the covenant was enforceable.
- Years later, a homeowner who had signed the covenant sold his house to Carl Hansberry. Anna Lee, another homeowner, tried to enforce the covenant against the Hansberrys and argued the sale should be void.
- The Illinois courts said the covenant could not be challenged because of res judicata (the prior judgment) since the seller was part of the earlier class action, and the class had not properly addressed new arguments about the covenant.

The key issue
- If a class action is used, are all members properly represented? Some class members in Burke v. Kleiman wanted to enforce the covenant, while others did not. Were they adequately represented as one group?

The Supreme Court ruling
- The Court reversed the Illinois decision.
- It held that applying res judicata in this way violated the Due Process Clause of the Fourteenth Amendment.
- Because the class in Burke v. Kleiman had conflicting interests, those class members could not be said to be adequately represented by a single party. Binding the seller to that prior judgment would deprive him of due process.

What happened after
- The case helped establish an important civil procedure rule: a class action cannot bind someone whose interests were not adequately represented.
- Later, in Shelley v. Kraemer (1948), the Supreme Court ruled that racially restrictive covenants, when enforced by state courts, are unconstitutional.

Note
- The case was successfully argued by civil rights attorney Earl B. Dickerson.