Robinson v. Metro-North Commuter R.R. Co.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
All 54 flagged citations have been read; the 2 confirmed treatments are listed below. The Supreme Court barred certification of monetary claims under that rule when the monetary relief is not incidental to classwide injunctive or declaratory relief. The Second Circuit expressly recognized the change in Amara v. CIGNA Corp. (2014). Courts continue to cite Robinson's separate discussion of certifying liability issues. Two versions of Amara repeat its recognition of the Supreme Court's act; that treatment is attributed to Wal-Mart itself. The staged Ricci v. DeStefano rehearing order contains no citation to Robinson and supplies no adverse treatment. The 2007 Ninth Circuit Dukes panel opinion was withdrawn and supplies no live treatment.
54 later cases cite Robinson v. Metro-North Commuter R.R. Co.; 54 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Robinson v. Metro-North Commuter R.R. Co.?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in part
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The Supreme Court ruled out Rule 23(b)(2) certification of monetary claims when the money is not incidental to classwide injunctive or declaratory relief, displacing Robinson's broader standard.
Wal-Mart Stores, Inc. v. Dukes · Supreme Court of the United States · filed
We also conclude that respondents’ claims for backpay were improperly certified under Federal Rule of Civil Procedure 23(b)(2). Our opinion in Ticor Title Ins. Co. v. Brown, 511 U. S. 117, 121 (1994) (per curiam), expressed serious doubt about whether claims for monetary relief may be certified under that provision. We now hold that they may not, at least where (as here) the monetary relief is not incidental to the injunctive or declaratory relief.
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Declined to follow
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The Eleventh Circuit declined to adopt Robinson's rejection of the incidental damages standard for Rule 23(b)(2) certification.
Cooper v. Southern Co. · Eleventh Circuit · filed
... urge this Court to adopt the position taken by the Second Circuit, which has rejected the incidental damages standard. See Robinson v. Metro-North Commuter R.R., 267 F.3d 147, 167 (2d Cir. 2001). However, Murray unambiguously explained that the Allison incidental damages standard is the proper legal standard to analyze certification under Rule 23(b)(2) in the Eleventh Circuit. We are bound to apply the standard outlined in Murray, since one panel of this Court cannot overrule another.
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