Martin_v._Wilks
Martin v. Wilks
1989 United States Supreme Court case
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.[1]
| Martin v. Wilks | |
|---|---|
| Argued January 18, 1989 Decided June 12, 1989 | |
| Full case name | Martin, et al. v. Robert K. Wilks, et al. |
| Citations | 490 U.S. 755 (more) 109 S. Ct. 2180; 104 L. Ed. 2d 835; 1989 U.S. LEXIS 2849 |
| Case history | |
| Prior | In re Birmingham Reverse Discrimination Emp't Litig., 833 F.2d 1492 (11th Cir. 1987); cert. granted, 487 U.S. 1204 (1988). |
| Holding | |
| Respondents are not precluded from challenging the employment decisions taken pursuant to the consent decrees. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Rehnquist, joined by White, O'Connor, Scalia, Kennedy |
| Dissent | Stevens, joined by Brennan, Marshall, Blackmun |
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.
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 declared that the white firefighters should have been joined as parties to the original proceeding under the Federal Rules of Civil Procedure Rule 19(a).
- Fairless, M. J. (1990). "Martin v. Wilks: Playing by the Rules in Employment Discrimination Litigation". Missouri Law Review. 55: 703. ISSN 0026-6604.
- Issacharoff, Samuel (1991). "When Substance Mandates Procedure: Martin v. Wilks and the Rights of Vested Incumbents in Civil Rights Consent Decrees". Cornell Law Review. 77: 189. ISSN 0010-8847.
Works related to Martin v. K Wilks Personnel Board of Jefferson County Alabama at Wikisource- Text of Martin v. Wilks, 490 U.S. 755 (1989) is available from: Cornell CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)
