## Facts

- In 1955, a federal district court entered a permanent injunction against the University of Alabama’s Dean of Admissions, prohibiting denial of enrollment to the plaintiffs and similarly situated applicants solely because of race or color.
- The injunction expressly applied to the dean and to his servants, agents, assistants, employees, and others acting in concert with him.
- The original enjoined dean resigned from office in 1961.
- A successor dean assumed the admissions position in 1961.
- In 1963, the successor dean petitioned the court for a construction of whether the 1955 injunction remained effective against him in his official capacity.

## Issues

1. Whether an injunction entered against a public officer in his official capacity binds the officer’s successor who was not individually named in the original decree.
2. How Fed. R. Civ. P. 65(d) (persons bound by injunctions) and amended Fed. R. Civ. P. 25(d) (automatic substitution of public officers) affect the continuing force of such an injunction.

## Decision

- The court held that the 1955 permanent injunction remained in force and bound the successor Dean of Admissions in his official capacity.
- The court concluded that no new injunction or formal substitution order was required for the decree to apply to the successor.
- The court construed the injunction as continuing to restrain the admissions office from denying enrollment solely on account of race or color.

## Legal Principles

- Under Fed. R. Civ. P. 25(d), when a public officer sued in an official capacity resigns or otherwise leaves office, the successor is automatically substituted as a party; omission of a formal substitution order does not affect the substitution.
- Under Fed. R. Civ. P. 65(d), an injunction binds the parties and those acting as their officers, agents, servants, employees, and others in active concert or participation with actual notice of the order.
- An injunction directed to an official interest continues to bind a successor who has notice and succeeds to the enjoined official function, and disobedience may be punishable by contempt.

## Conclusion

The court confirmed that a permanent injunction entered against a public official in an official-capacity suit operates against the office and continues to bind successor officeholders with notice, ensuring continuity of court-ordered nondiscrimination in university admissions.


Lucy v. Adams, 224 F. Supp. 79 (N.D. Ala. 1963)