Discrimination · Federal · Title VII
Wal-Mart Stores, Inc. v. Dukes
564 U.S. 338 · Supreme Court of the United States · 2011
Roughly 1.5 million current and former female employees sought certification of a nationwide class alleging that the company's practice of delegating pay and promotion decisions to local managers produced discriminatory outcomes.
The Court held the class lacked commonality: a policy of discretion, without a common mode of exercising it, does not by itself bind the members' claims together.
Class certification reversed
Reported outcome
Certification reversed; the class could not proceed in that form.
Completeness reading
66/100
ignita-completeness-v1 · illustrative
Preview. Not legal advice. Attorney-reviewed: false.
The events, kept in order.
Drawn from the reported decision. Nothing is interpreted at this stage — each entry simply holds when it happened and what happened.
Practice
Pay and promotion discretion delegated locally
Local managers exercised substantial discretion over pay and advancement.
Protected activity or key conduct
Evidence
Statistical and anecdotal proof offered
Regional statistical disparities and roughly 120 individual affidavits were submitted for a class of about 1.5 million.
Gap
No common mode of exercising discretion shown
Nothing tied the individual decisions to a single company-wide practice.
Outcome
Commonality not established
The nationwide class was held not certifiable on this record.
What the engine reads here
The cautionary case in the library. Scale is not a pattern. What was missing was a shared mechanism connecting individual decisions — which is precisely what dated, source-linked individual records can supply and statistics alone cannot.
Pattern and class signal
Class denied. Read this beside Tyson Foods: aggregate numbers succeed when a common practice is documented and fail when only discretion is.
Preview. Not legal advice. Attorney-reviewed: false.
Your own record
Every matter here began as small, ordinary entries someone almost didn't keep.