## Facts

- A state-court class action challenging racial segregation in the Los Angeles Unified School District (LAUSD) resulted in a final judgment approving a revised desegregation plan that did not include mandatory reassignment or busing.
- The state proceedings concluded without an appeal from the class plaintiffs after approval of the revised plan.
- The Los Angeles Branch NAACP and related branches later filed a federal class action on behalf of Black and Hispanic LAUSD students.
- The federal complaint alleged LAUSD and local officials intentionally created and maintained a segregated school system in violation of the U.S. Constitution and sought federal remedial relief.
- LAUSD moved for summary judgment, asserting the prior state judgment precluded the federal action.
- The federal district court denied summary judgment, and LAUSD pursued an interlocutory appeal; the Ninth Circuit reheard the case en banc.

## Issues

1. Whether the final state-court desegregation judgment precluded the NAACP’s federal class action against LAUSD under res judicata (claim preclusion).
2. Whether the federal plaintiff class was identical to, or in privity with, the class bound by the state-court judgment.
3. Whether the federal claims of intentional de jure segregation were the same cause of action as, or could have been litigated in, the earlier state proceedings.
4. Whether intervening developments in federal constitutional doctrine avoided claim preclusion.

## Decision

- The en banc Ninth Circuit reversed the district court’s denial of summary judgment.
- The court held the federal class action was barred by res judicata based on the final state-court judgment.
- The court concluded the relevant classes overlapped substantially and the federal plaintiffs were bound by the earlier class judgment.
- The court determined the federal claims were not materially new because they fell within the scope of claims litigated, or that could have been litigated, in the state action.
- The case was remanded for disposition consistent with claim preclusion (effectively dismissal of the barred federal claims).

## Legal Principles

- A final judgment in a prior class action can bind absent class members and preclude later litigation by a substantially identical class concerning the same underlying controversy.
- Claim preclusion extends to claims actually litigated and those that could have been raised in the prior action as part of the same cause of action.
- Federal courts must give state-court judgments the same preclusive effect they would receive under the rendering state’s law, absent a recognized exception.
- Changes or clarifications in governing constitutional standards generally do not permit a new, separate lawsuit by the same class over the same events; the proper course is appeal or authorized modification within the original litigation framework.

## Conclusion

The Ninth Circuit held that the NAACP’s federal desegregation class action against LAUSD could not proceed because a prior state-court class action had already produced a final judgment resolving the desegregation dispute, binding the overlapping class and precluding relitigation of claims that were or could have been asserted earlier.


Los Angeles Branch NAACP v. Los Angeles Unified Sch. Dist., 750 F.2d 731 (9th Cir. 1984) (en banc)