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Civil Procedure Keyed to Mueller
Allen v. International Truck and Engine Corp.
Facts
Twenty-seven current and former black employees (plaintiffs) at a plant of International Truck & Engine Corp. (Int’l Truck) (defendant) alleged that Int’l Truck fostered a hostile work environment in which white employees harassed and mistreated black employees with impunity. Requesting monetary damages and equitable relief, the plaintiffs sought to be certified as representatives of a class of current and former black employees at the plant, numbering 350 in all. Despite finding that the plaintiffs had satisfied the class action prerequisites set forth in Federal Rule of Civil Procedure (FRCP) 23(a), the district court denied certification under FRCP 23(b)(2) on the grounds that the plaintiffs’ request for damages conflicted with the unavailability of an opt-out option for class members and that certifying a class for equitable relief only would be overly difficult to manage, given the class members’ rights to a jury trial under the Seventh Amendment. The plaintiffs appealed the denial of certification under FRCP 23(f), which authorizes interlocutory appeals of class-certification decisions.
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