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CUTLER v. WAL-MART STORES, INC.
Court of Special Appeals of Maryland (2007) | 927 A.2d 1; 175 Md. App. 177
TL;DR: Former Wal-Mart employees sued for unpaid wages and missed breaks, seeking to form a class action. The court denied class certification, finding that individual questions about each employee's specific circumstances predominated over issues common to the group, making a class action unmanageable.
Legal Significance: This case illustrates Maryland's strict application of the predominance requirement for class certification under Md. Rule 2-231(b)(3). It demonstrates that claims requiring individualized proof of liability for each class member, such as those involving implied contracts or specific instances of off-the-clock work, will likely fail certification.