Cooper v. Federal Reserve Bank of Richmond

Facts

A federal court certified a class described as all black employees of Federal Reserve Bank of Richmond, Defendant employed since January 3, 1974, that were discriminated against because of their race. The District Court found that Defendant engaged in policies and practices of failing to pay black employees the same pay grade as white employees in Grades 4-5. In addition, the District Court found that Defendant did not engage in policies and practices of race discrimination as to other aspects alleged such as to warrant relief. Finally, the District Court found against some intervenors, but not the group of plaintiffs known as the “Baxter petitioners.” The Baxter petitioners subsequently brought individual lawsuits alleging race discrimination. Defendant moved to dismiss on the grounds that Baxter petitioners were not in Grades 4 or 5 and thus were bound by the District Court’s previous determination. The District Court denied the motion to dismiss. On interlocutory appeal, the Court of Appeals reversed, finding that under the doctrine of res judicata, the Baxter petitioners were precluded from bringing individual lawsuits. Baxter petitioners appealed.