Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011)
Wal-Mart Stores, Inc. v.
Does a class action certification under Federal Rule of Civil Procedure 23(b)(2) require a demonstration of commonality among class members, and if so, what constitutes sufficient commonality?
Under Federal Rule of Civil Procedure 23(a), a class action must meet four requirements, including commonality, which necessitates that there be questions of law or fact common to the class. Rule 23(b)(2) further requires that the party opposing the class has acted or refused to act on grounds that apply generally to the class.
The Supreme Court held that the class certification was improper under Rule 23(b)(2) due to the lack of commonality among the class members. The Court found that the plaintiffs did not demonstrate sufficient commonality, as there was no significant proof that Wal-Mart operated under a general policy of discrimination.
This case is significant for law students as it clarifies the standards for demonstrating commonality in class action lawsuits. It underscores the necessity for plaintiffs to provide concrete evidence of a cohesive policy or practice causing discrimination to justify class-wide treatment. The ruling set a precedent that affects how future class action lawsuits are structured, influencing the scope of permissible claims and the evidence required to pursue such claims.