Federal Practice Manual for Legal Aid Attorneys: 7.2.13 Rule 23(b)(2) Classes
Class certification under Rule 23(b)(2) is far more common than (b)(1) classes and the traditional class action tool for poverty lawyers. Under Rule 23(b)(2), the class must show that the defendant acted in a way “generally applicable” to class members, making classwide declaratory and injunctive relief appropriate.3571 In Wal-Mart, the Court held: