Dionne v. Bouley
United States Court of Appeals for the First Circuit
757 F.2d 1344 (1985)

- Written by Mary Phelan D'Isa, JD
Facts
Rose Dionne (plaintiff), the class representative, sought class certification in her action for declaratory and injunctive relief against Gerard Bouley, chief clerk of the district courts of the State of Rhode Island (defendant), challenging the constitutionality of Rhode Island’s post-judgment garnishment procedure. The putative class included all Rhode Island judgment debtors subject to the challenged procedures and whose funds may have been exempt in whole or in part under state or federal law. The district court denied class certification on the grounds that any injunctive or declaratory relief awarded would benefit all those similarly situated and would be identical regardless of whether the action proceeded as a class action. Dionne challenged the court’s denial of class certification. Dionne argued that the court erred in applying a necessity requirement to its class-certification analysis under Federal Rule of Civil Procedure 23(b)(2).
Rule of Law
Issue
Holding and Reasoning (Campbell, C.J.)
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