Abiding Dukes: Putative Classes Held To Higher Standards

Law360, New York (July 9, 2012, 2:11 PM EDT) -- On June 12, 2012, Judge Michael Anello of the U.S. District Court for the Southern District of California issued an order denying the motion for class certification (Rec. Doc. 106) in Edwards v. Ford Motor Co., Case No. 11-CV-1058-MMA(BLM). Anello denied the motion because he found that while Rule 23(a)’s commonality requirement was met, Rule 23(b)(3)’s predominance requirement was not.

This case is yet another example of the significant impact of Wal-Mart Stores Inc. v. Dukes on issues of class certification, and shows that a year...
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