HANSBERRY V. LEE
311 U.S. 32 (1940).
NATURE OF THE CASE: This was a class action for the enforcement of a racially restrictive
covenant.
FACTS: In a prior case involving a racially restrictive covenant, the Illinois Supreme
Court determined that the covenant was valid and that because the action was a class action,
all members of the class would be bound by the decision of the court. Hansberry (D), a
black, purchased land from a party who had signed the same restrictive covenant forbidding
the sale of the land to blacks. Lee (P), one of the parties to that covenant, sought to
enforce the covenant based on the prior case involving the same covenant. D claimed that he
and the party selling him the house were not bound by the res judicata effect of the prior
decision, because they were not parties to that litigation. D alleged a violation of their
due process rights. The court held that the prior decision of the Illinois Supreme Court
would have to be challenged directly in order to have it set aside or reversed. The court
held that the prior action was binding on D. The case was appealed to the U.S. Supreme
Court.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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