Wal-Mart Stores Inc. V. Dukes Case Summary

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Case Name: Walmart Stores, INC. V. Dukes
Case Citation: 131 S. Ct. 2541 (2011)
Summary of the Facts of the Case: Betty Dukes from Pittsburg, California worked at Wal-Mart as a “greeter” had filed a class action lawsuit along with five other women in which they alleged the company’s nationwide policies resulted in lower pay for women than in comparable positions and longer wait for management promotions than for men. Wal-Mart has disputed that the court should require employees to file on an individual basis, opposing the class actions of this size – formed under the Rule 23(a)(2) of the federal rules of civil procedure – are essentially unmanageable and unduly costly. The U.S. Court of Appeals for the Ninth Circuit has three times upheld the class certification. Walmart also argued that class certification was improper under Federal Rule of Civil Procedure 23(b)(2) because the employees primarily seek monetary compensation in the form of back pay, and Rule 23(b)(2) does not authorize
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Is a claim for monetary relief permitted to be certified under Federal Rules of Civil Procedure 23 (b)(2) if it is not secondary to obtaining an injunction or declaration?
Holding in The Case: The Supreme Court ruled in a 5-4 decision due to the fact of the certification order is not consistent with rule 23 (a). and the certification order is not consistent with rule 23(b) (2).
Reasoning: The class should not have received certification under Rule 23(b) (2) because the Plaintiffs failed to establish the prerequisites to certification which is commonality. And Rule 23 (b) (2) does not encompass monetary relief. The plaintiffs are wrong in suggesting that the rule 23 (b) (2) requirement that the district court determine whether injunctive relief predominates over monetary relief. It serves essentially the same purposes as the procedural safeguards mandated in (b) (3)