In the Wal-Mart case, Betty Dukes v. Wal-Mart Stores, Inc., the U.S. Supreme Court denied the class action certification. The court ruled that plaintiffs over 1.5 million women accusing Wal-Mart of systemic sex discrimination did not satisfy an essential class-action requirement in the Federal Rules of Civil Procedure 23, known as commonality. This effectively concluded the case and returned the plaintiffs to square one. Commonality is a legal standard that determines whether a group of plaintiffs can be treated as a single class in a class action lawsuit. Under Rule 23, one of the key requirements for certifying a class is that the claims of the class members must share common questions os law or fact. That means that the questions raised by the plaintiffs must be sufficiently alike so that they can be litigated together and not individually. In the case of Dukes, the court decided that the plaintiffs failed to demonstrate that their discrimination claims were adequately unified to meet the requirements for commonality. The class consisted of 1.5 million women who allegedly suffered different kinds of discrimination; for example, different pay, different managers, and different regions. The Court felt that these individual differences meant plaintiffs did not share a common legal or factual issue that could be resolved in a single lawsuit. The majority opinion written by Justice Antonin Scalia relied heavily on this lack of commonality among plaintiff’s claims. Scalia argued that to have a class action, the plaintiffs must show that they suffered under a common discriminatory treatment or the same cause of discrimination in a manner so that one solution would be applicable. Emphasizing, he said, “Women weren’t universally denied the same promotion or the same raise. The alleged discrimination wasn’t the result of a single policy or some sort of centralized plan. It was instead based on the discretionary decisions by individual managers at individual stores.” And there lacked any “glue” to hold together all plaintiffs’ claims in a single class action. Scalia said that without a clear common discriminatory practice that applied uniformly to all women across the country, it was impossible to adjudicate their claims as a single class. The courts decision focused on whether the plaintiffs claims were sufficiently connected, or “common” in a way that would justify handling them together in a single lawsuit. Scalia argued that the size of the class, and the diversity of their experience, made this impossible. The plaintiffs had sought both injunctive relief-that is, a change in Wal-Mart practices-and monetary damages (back pay for the discrimination), but the court ruled that because they were not all subject to the same policies or treatment these claims could not be addressed in one class action. Justice Ruth Bader Ginsburg, writing for the dissent, felt that commonality had been interpreted incorrectly by the Court. According to her, what the claims of the women shared in common was the systematic gender bias prevailing at Wal-Mart, though unwritten as policy, everywhere within the firm. She said the plaintiffs need not prove that each individual faced the same discrimination but only prove that their claims were based upon a common discriminatory practice. This practice of male favoritism with respect to pay, promotion, and other opportunities was, in her view, sufficient to satisfy the commonality requirement. She noted that discretionary practices may also support systemic discrimination. The commonality requirement is core to class actions because it ensures that the court can effectively address the plaintiffs claims in a manner that is efficient and fair. If the claims in a way are too individual or too diverse, then the court may determine that the issues are better addressed in separate lawsuits. For example, if different workers at different Wal-Mart stores faced discrimination in radically different ways, each woman would have a different story about how she was discriminated against, making it more difficult for the court to address all their issues in one case.