The U.S. Supreme Court's June 20 decision in Wal-Mart Stores Inc. v. Dukes et al. dealt a huge blow to plaintiffs seeking to certify employment discrimination class actions under Federal Rule of Civil Procedure 23, as well as consumer, antitrust and other class actions. The heavily publicized case involved a proposed 1.5 million-person class of female Wal-Mart employees seeking to bring disparate-impact and pattern-or-practice claims for discrimination in promotions and compensation.