After the Supreme Court’s decision in Wal–Mart Stores, Inc. v. Dukes, 131 S.Ct. 2541 (2011) was announced, many believed class certification of employment classes or Rule 23b(2) classes would be a thing of the past. Developments after Dukes, however, demonstrate that, to the contrary, courts have found ways to avoid the impact of Dukes. Dukes … Continue Reading