794
Opinion of the Court
did not provide representation sufficient to make up for the fact that petitioners neither participated in, nor had the opportunity to participate in, the earlier action. Pp. 799-802. (c) This Court may assume that if petitioners had relied on their taxpayer status to complain about an alleged misuse of public funds or about other public action having only an indirect impact on their interests, the State would have enjoyed wide latitude in limiting their opportunity to make their case. However, because petitioners present a federal constitutional challenge to the State's attempt to levy personal funds, the Court is not persuaded that the nature of their actions permits it to deviate from the traditional rule that an extreme application of state-law res judicata principles violates the Federal Constitution. Pp. 802-805. 662 So. 2d 1127, reversed and remanded.
Stevens, J., delivered the opinion for a unanimous Court.
William J. Baxley argued the cause for petitioners. With him on the briefs was Joel E. Dillard.
William M. Slaughter argued the cause for respondents. With him on the brief was Richard H. Walston.*
Justice Stevens delivered the opinion of the Court. In Hansberry v. Lee, 311 U. S. 32, 37 (1940), we held that it would violate the Due Process Clause of the Fourteenth Amendment to bind litigants to a judgment rendered in an earlier litigation to which they were not parties and in which they were not adequately represented. The decision of the Supreme Court of Alabama that we review today presents us with the same basic question in a somewhat different context.
I
Jason Richards and Fannie Hill (petitioners) are privately employed in Jefferson County, Alabama. In 1991 they filed a complaint in the Federal District Court challenging the validity of the occupation tax imposed by Jefferson County
*Richard Ruda and James I. Crowley filed a brief for the National Association of Counties et al. as amici curiae urging affirmance.
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