Class And Collective Actions In A Post-Dukes World

Law360, New York (April 22, 2015, 10:46 AM EDT) -- Citibank NA's victory against putative class and collective actions in Citibank v. Ruiz, No. 10 CIV. 5950 KPF RLE (S.D.N.Y. March 19, 2015) represents a growing trend among trial courts of raising the bar on certification. Personal bankers from California, New York, Washington and other states alleged Citibank withheld overtime pay under a nationwide scheme encouraging off-the-clock work. Although finding "systematic violations at the branch level," the district court held the plaintiffs failed to connect those violations to an unlawful, nationwide company practice. The court denied the plaintiffs' bid for class certification of state law claims and decertified a collective action under the Fair Labor Standards Act....

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