4th Circ. Strips Class Cert. In Pinkerton OT Case

Law360, New York (March 15, 2013, 2:05 PM EDT) -- The Fourth Circuit on Thursday blasted a lower court's order certifying a class of Pinkerton Government Services Inc. guards seeking off-the-clock compensation for work performed at Andrews Air Force Base, saying it failed to conduct a “rigorous analysis” required under Dukes.

A three-judge panel vacated U.S. District Judge Peter J. Messitte's January 2012 class certification order, saying the judge abused his discretion by failing to provide a rigorous analysis “sufficient to enable us to conduct meaningful appellate review.”

The panel added that the order failed the...
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