The Way Forward after Wal-Mart

The article discusses the case Wal-Mart Stores Inc. v. Dukes, in which the U.S. Supreme denied class action certification in its ruling. It informs that the decision of Supreme Court was opposed by some people in liberal circles, also including Justice Ruth Bader Ginsburg. It presents information that the Justice agreed to a point that a class action certification is not possible under the Federal Rule of Civil procedure 23 (b) (2), which governs class actions in which injunctive relief.