The U.S. Court of Appeals for the Ninth Circuit (covering California and eight other Western states) in Dukes v. Wal-Mart, 2010 WL 1644259 (9th Cir. April 26, 2010), affirmed the certification of the largest class action in history. The plaintiffs claim Wal-Mart has “rolled back” pay and promotions for women across the country. At the time of certification, the class encompassed approximately 1.5 million women, and damages could reach the multi-billion dollar range. While affirming certification, the Ninth Circuit remanded the case for the lower court to reconsider whether individuals no longer employed by Wal-Mart at the time the case was filed can remain in the class and whether the class can pursue punitive damages.