Richards v. Jefferson County, Alabama

Summary

Justice Stevens delivered the unanimous opinion holding that due process prohibited Alabama from binding petitioners to an earlier judgment upholding a county occupation tax because they received neither notice nor constitutionally adequate representation in that litigation. The earlier taxpayers had not purported to represent absent taxpayers, and their shared interests did not make the prior suit a representative proceeding. The public importance of the tax and governmental reliance on the earlier judgment did not justify denying petitioners an opportunity to challenge a levy on their own funds. The Court reversed and remanded without deciding the underlying equal protection challenge. There were no separate opinions.