West v. Randall(1820)
As previously mentioned, Westwas one the earliest class actions in the United States. The case concerned the estate of a Revolutionary War General, William West. West, interestingly, was involved in the first Supreme Court case in 1791,West v. Barnes. However, he passed in 1814, and there was a dispute as to who should be made a party to his estate. Justice Joseph Story is famous for his decision and usually receives credit for formulating the modern standards for class actions as he stated,"It is a general rule in equity, that all persons materially interested, either as plaintiffs or defendants in the subject matter of the bill ought to made parties to the suit, however numerous they may be."
Hansberry v. Lee(1940)
Although not a class action itself, Hansberryis an important case for class actions as the Supreme Court ruled thatres judicata, or claim preclusion, does not apply to an individual whose interests who not adequately represented in a prior class action. BeforeHansberry, there was a 1934 class-actioncase,Burke v. Kleiman, where the class had been homeowners who had signed a racially-restrictivecovenant, and the suit sought to enforce the covenant against an individual who was attempting to lease his home to an African American. The Illinois state court found the covenant enforceable. Six years later,an owner who had signed the covenant attempted to sell his home to Carl Hansberry. The Illinois courts stated that because the seller had been a member of the class inBurkehe was bound by the judgment. However, the SupremeCourt stated that members of the class inBurkewould have had conflicting interests: some homeowners would have wanted the covenant to beenforced, and somewould not have wanted it to be enforced. The Court continued in statingthat the interests of the class members could not have been adequately represented and that binding the defendants (the seller and Hansberry)to a judgment in a case in which they were not adequately represented would violate their due process rights under the Fourteenth Amendment.
Walmart Stores, Inc. v. Dukes(2011)
In 2000, Betty Dukes, aWalmart employee in California, claimed sex discrimination as she had been employed forsix years and hadpositive performance reviews butwas denied the training she needed to advance to a higher salaried position.In2001, the lawsuit began in the US District Courtin San Francisco. The plaintiffs sought to represent 1.6 million women, including women who were currently working or who had previously worked in a Walmart store since December 26, 1998. The District Court certified the class under Rule 23(b)(2), and the Court of Appeals affirmed. On appeal, the Supreme Court ruled that the class should not have been certified under Rule 23(a)(2), saying the plaintiffs did not have enough in common to constitute a class.
