Walters v. Reno
United States Court of Appeals for the Ninth Circuit
145 F.3d 1032 (9th Cir. 1998)
The INS could issue unappealable final orders, typically resulting in deportation, against aliens accused of document fraud who failed to request a hearing within 60 days of receiving certain notice forms that plaintiffs (Walters, et al.) claimed were confusingly worded and inadequately explained their rights; the district court certified a class of roughly 4,000 affected aliens and granted summary judgment and injunctive relief, and the government appealed the class certification, arguing individual variation among class members and resulting administrative complexity made certification inappropriate.
Whether issues and facts among class members must be identical for a class to be certified under Federal Rule of Civil Procedure 23(b)(2).