9th_Cir_seal.jpgCo-authored by Brandon McKelvey and Fred Sanderson 

Citing the Supreme Court’s recent decision in Dukes v. Wal-Mart, on December 30, 2011, the Ninth Circuit vacated its prior decision reversing a district court’s denial of class certification under Federal Rule of Civil Procedure 23(b)(2). The Ninth Circuit’s unpublished memorandum in Sepulveda v. Wal-Mart Store, Inc., indicates that the Supreme

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