The Supreme Court's decision in Erica P. John Fund, Inc. v. Halliburton Co., ___ U.S. ___ (Jun. 6, 2010), handed down on Monday, is narrowly drawn. The decision is highly relevant to securities class actions, but nothing in it can be expected to impact other types of class actions.
The opinion did not discuss the Eisen case (or even mention it), notwithstanding the statement of issues in the cert. petition. The Court seems to have remanded all the juicy issues back to the Fifth Circuit:
To the extent Halliburton has preserved any further arguments against class certification, they may be addressed in the first instance by the Court of Appeals on remand.
Slip op. at 9.
According to SCOTUSblog, the Court is expected to hand down additional opinions this morning. Dukes v. Wal-Mart could be among them.