Last year, in Shady Grove Orthopedic Associates, P. A. v. Allstate Ins. Co., 559 U.S. ___, 130 S.
Absent Class Members Suing in State Court Are Not Bound by Prior Federal District Court Decision
Recently, in <i>Smith v. Bayer Corp.</i>, the Supreme Court addressed whether a federal court decision denying class certification had any preclusive effect on efforts by other plaintiffs to seek certification in state court under nearly identically worded state procedural rules.
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