Eleventh Circuit Addresses Geographically Diverse Employment Classes

In Dukes v. Wal-Mart, the Northern District of California certified a nationwide class of over 1.5 million current and former female employees of Wal-Mart, working in 3,400 stores spread across the United States. In Dukes, the court found that the failure to promote and unequal pay claims of that class satisfied the commonality and typicality requirements for certification under Federal Rule of Civil Procedure 23(a). Additionally, the Northern District of California certified claims for injunctive relief, compensatory and punitive damages under F.R.C.P. ("FRCP") 23(b)(2), finding that the claims for equitable relief predominated over the claims for money