The Rule 23(b)(2) class certification standard requires that a class be sufficiently cohesive so that injunctive and declaratory relief may apply to the class as a whole. Punitive damages are inappropriate for a 23(b)(2) class. Class certification proceedings do not require evidence to be in a form that would be admissible at trial.
Jacobsen v. Allstate Ins. Co., 2013 MT 244,
0 Mont. L. Rev.
Available at: http://scholarship.law.umt.edu/mlr/vol0/iss2/4