Jermyn v. Best Buy Stores, L.P.
This case addresses Defendant Best Buy's second motion to decertify a class of New York customers who alleged the company denied valid price match requests through a secret corporate "Anti-Price Matching Policy." The court had previously certified the class for both injunctive relief under Rule 23(b)(2) and money damages under Rule 23(b)(3). Best Buy's motion for decertification was based on the Supreme Court's decision in Wal-Mart Stores, Inc. v. Dukes, which clarified standards for class commonality and the appropriateness of monetary claims in Rule 23(b)(2) classes. The court denied the motion, distinguishing Dukes by noting that the plaintiffs here successfully alleged and provided substantial proof of a specific, centralized illegal corporate policy, unlike the broad discretion at issue in Dukes. Furthermore, the court emphasized that its certification involved separate classes for injunctive and monetary relief, thus not violating Dukes' guidance on combined (b)(2) claims.