At a policy symposium sponsored by the RAND Institute for Civil Justice, CCL’s Robert S. Peck spoke on “The Future of Class Actions after Wal-Mart v. Dukes” Oct. 16 in Santa Monica, California. In the Wal-Mart case in 2011, the Supreme Court of the United States tightened the commonality requirements for the certification of class actions under Federal Rule of Civil Procedure 23 and decertified the largest federal employment class action ever assembled. Since the decision, defendants have tried unsuccessfully to apply the same reasoning to state class actions as a matter of due process. Peck spoke about these cases and why the Court’s new construction of Rule 23 should not affect class actions tried in state courts.