Betty Dukes and five other women, who were Wal-Mart employees, filed a class-action lawsuit against alleged infringement upon civil rights done by Wal-Mart. They argued on behalf of themselves and 1.5 million women—who had been employed by Wal-Mart after December 26, 1998—that Wal-Mart implemented corporate policies that resulted in nationwide discrimination against employed females. They claimed there was a moratorium in promotion in comparison to male employees; furthermore, they contended females were meted out lower pay when it came to doing the same job as their male coworkers. Wal-Mart rebutted by arguing the court ought to require individual lawsuits from Wal-Mart employees because the size of the class made it impossible to …show more content…
Do the claims for monetary relief satisfy Rule 23(b)(2)'s requirements for certification of a mandatory non-opt-out class?
Holding:
No. By a rule of 5-4, the Supreme Court ruled in favor of Wal-Mart Stores, Inc.
Reasoning:
1. The Supreme Court found the plaintiff's failed to fulfill the criterion of proving commonality in the issue regarding whether all female members were subject to the same discrimination in regards to Wal-Mart's employment policy.
2. The Ninth Circuit had previously established a “predominance test” defining permissibility of claims under Rule 23 (b), allowing claims to be authorized assuming they were not primary to the claims for injunctive relief. Claims for monetary relief in this case are not valid under Federal Rules of Civil Procedure 23 (b)(2); the monetary relief is not concomitant to the requested injunctive or declaratory relief.
Analysis:
This case was unique because it was the biggest class action lawsuit to have ever been filed. It established the burden of fulfilling the criterion of commonality. District courts will now have to scrutinize all cases where commonality is alleged, to assure the common inquiries proposed in the suit will provide a response that is applicable to all members of said