Ohio Supreme Court Reverses Class Certification

On November 5, 2013, the Ohio Supreme Court issued the second in a trilogy of decisions involving class actions in the Dukes v. Wal-Mart era. In Cullen v. State Farm Mutual Automobile Insurance Company, the Court reversed the Eighth District Court of Appeals, and ruled that the action did not satisfy Rule 23(B)(2) because injunctive relief was only incidental to the monetary relief sought, or Rule 23(B)(3) because a rigorous analysis demonstrated that individual questions predominate over issues common to the class. We will be reporting more about this case in the days ahead.

Civil Rule 23 Requirements, Ohio Class Action Law, Wal-Mart v. Dukes