Seventh Circuit -- Tammy Boyd v. Meriter Health Serv

Certification of 23(b)(2) class action upheld despite diversity of subclass claims - statutory language requiring the deft to have acted the same to all members refers to the subclasses.

Walmart v. Dukes limits on uniformity of redressibility apply to the subclass, not the class.

Formulaic reformation of the larger ERISA plan, although resulting in different awards, is not individualized monetary relief for the purposes of class certification.

Potential conflicts of interest on the merits not substantial enough to bar certification..

Tammy Boyd v. Meriter Health Serv