Second Circuit: Supreme Court's Comcast Ruling Does Not Require Wage & Hour Class Action Damages Be Measurable Classwide | Practical Law
In Roach v. T.L. Cannon Corp., the Second Circuit reversed a district court’s denial of Rule 23 class certification in a wage and hour case, holding that a 2013 Supreme Court decision did not require that class certification only be granted when damages are measurable on a classwide basis. As the district court’s decision was based solely on a misreading of the Supreme Court decision, the Second Circuit remanded and reaffirmed existing second circuit case law holding that Rule 23 class certification cannot be denied solely because damages must be determined on an individual basis.