Federal Practice Manual for Legal Aid Attorneys: 9.2.22 Challenges to Consent Decrees
In Martin v. Wilks, the Supreme Court held that a consent decree adjudicated only the rights of the parties to the decree.4455 The Court, therefore, allowed those persons who were adversely affected by the operation of the decree to challenge actions taken pursuant to the decree even though they failed to intervene in the litigation from which the decree arose.