Second Circuit Vacates ERISA Class Action Certification Based on Wal-Mart v. Dukes

On February 6, 2012, the Court of Appeals for the Second Circuit in Nationwide Life Ins. Co. v. Haddock, Case No. 10-4237-cv, vacated and remanded for reconsideration a district court’s ERISA class action certification issued pre-Wal-Mart Stores, Inc. v. Dukes, 131 S. Ct. 2541 (2011).   

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