Cite as: 526 U. S. 160 (1999)
Opinion of the Court
B
The State, in opposing Bell's petition for certiorari, argued that the Alabama Supreme Court's decision rested upon an adequate state ground, namely, state-law principles of res judicata. It now believes, however, that the Alabama Supreme Court's decision rejected the plaintiffs' claims on their merits and relied upon Reynolds Metals under principles of stare decisis, not res judicata. Brief for Respondents 3. For that reason, the State "offer[s] no defense of the decision as a valid application of the doctrine of res judicata." Ibid. Nor do we believe a valid defense could be made. See Richards v. Jefferson County, supra.
In Richards, we considered an Alabama Supreme Court holding that state-law principles of res judicata prevented certain taxpayers from bringing a case (which we will call Case Two) to challenge on federal constitutional grounds a state tax that the Alabama Supreme Court had upheld in an earlier case (Case One) brought by different taxpayers. We held that the Fourteenth Amendment forbade this "extreme" application of state-law preclusion (res judicata) principles, id., at 797, because the plaintiffs in Case Two were "strangers" to the earlier judgment, id., at 802.
We cannot distinguish Richards from the case before us. In Richards, we pointed out that the taxpayers in Case One "did not sue on behalf of a class; their pleadings did not purport to assert any claim against or on behalf of any nonpar-ties; and the judgment they received did not purport to bind any . . . taxpayers who were nonparties." Id., at 801. We added that the taxpayers in Case One did not understand their suit "to be on behalf of" the different taxpayers involved in Case Two, nor did the Case One court make any special effort "to protect the interests" of the Case Two plaintiffs. Id., at 802. As far as we are aware, the same can be said of the circumstances now before us. The two relevant cases involve different plaintiffs and different tax years. Neither is a class action, and no one claims that there
167
Page: Index Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: October 4, 2007