Quick Summary
Dukes (plaintiff) and two other individuals, both current or former employees of Wal-Mart Stores, Inc. (defendant), represented a potential class action that encompassed about 1,500,000 current and former female Wal-Mart employees. They alleged gender discrimination in violation of Title VII of the Civil Rights Act, prompting an examination of whether the class certification of the plaintiff adhered to Federal Rules of Civil Procedure.
Facts of the Case
Wal-Mart is the largest private employer in the United States, operating over 3,800 stores (in 2011) and employing more than one million people. The company’s pay and promotion decisions are generally left to the discretion of local managers, who have broad authority in determining salaries and selecting individuals for promotions. The plaintiffs alleged that this discretionary power resulted in gender discrimination against female employees.
Betty Dukes, Christine Kwapnoski, and Edith Arana (plaintiffs) claimed they were denied equal pay or promotions based on gender. They argued that this discrimination was common to all female employees at Wal-Mart (defendant) due to a corporate culture that allowed bias against women to influence local managers’ decision-making.
Procedural History
On behalf of 1.5 million female employees, the plaintiffs sought class certification, consisting of all women employed at any Wal-Mart domestic retail store since December 26, 1998, who may have been subjected to Wal-Mart’s allegedly discriminatory policies. The District Court granted the motion for class certification, which the Court of Appeals subsequently affirmed. Wal-Mart appealed to the Supreme Court.
I.R.A.C. Format
Issue
Can a plaintiff class, comprised of more than one million individuals, be certified if they fail to demonstrate the commonality of issues or facts required under Federal Rules 23(a)(2), especially in cases where there is no evidence of a uniform discriminatory employment policy?
Rule of Law
Commonality among class members is a prerequisite for class certification under Rule 23(a), requiring a shared legal or factual issue that can be resolved collectively.
Rule 23(b)(2) class actions are limited to injunctive or declaratory relief, excluding individualized monetary claims.
Reasoning and Analysis
The plaintiffs failed to establish commonality among the class members. While statistical evidence showed disparities in pay and promotions between men and women at Wal-Mart, it did not prove that all the employees’ claims depended on common questions.
The Court emphasized that the existence of a corporate policy allowing discretion by local supervisors does not constitute a uniform employment practice that can be challenged through class action. Discretionary decision-making is common in many companies and does not necessarily lead to discrimination. Moreover, the anecdotal evidence provided by the plaintiffs was insufficient to infer an overall policy of discrimination.
Furthermore, the Court stated that the backpay claims could not be certified under Rule 23(b)(2) as they were individualized and did not qualify as incidental to the injunctive or declaratory relief sought. The Court explained that (b)(2) applies only when a single injunction or declaratory judgment can relieve each class member. Since each class member would be entitled to a different award of backpay, their claims did not satisfy Rule 23(b)(2).
Conclusion
The Court reversed the judgment of the Court of Appeals and held that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2). The Court found no commonality among the class members and that individualized monetary claims could not be certified under (b)(2).
Key Takeaways
- Class certification requires a showing of commonality among the members of the class and a demonstration that their claims depend on common questions.
- A plaintiff class cannot rely on statistical evidence alone to establish commonality, nor can individual anecdotes of discrimination.
- (b)(2) class actions are only appropriate when a single injunction or declaratory judgment can relieve each class member.
- Individualized monetary claims are unsuitable for certification under Rule 23(b)(2).
Relevant FAQs of this case
What is the commonality requirement in class certification?
The commonality requirement in class certification demands that there must be shared legal or factual issues that can be collectively resolved. In the context of a class action, this means that the class members’ claims should depend on common questions.
How does class size impact the commonality requirement?
Rule 23(b)(2) class certification is appropriate when a single injunction or declaratory judgment can relieve each class member. It is typically used in cases where the primary relief sought is injunctive or declaratory and applies generally to the entire class.
When is Rule 23(b)(2) class certification appropriate?
Rule 23(b)(2) class certification is appropriate when a single injunction or declaratory judgment can relieve each class member. It is typically used in cases where the primary relief sought is injunctive or declaratory and applies generally to the entire class.
References
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