In the case of Campbell v. National Railroad Passenger Corp., 311 F. Supp. 3d 281 (D.D.C. 2018), the U.S. District Court for the District of Columbia denied class certification in an employment discrimination class action case against Amtrak.  The Court concluded, among other reasons, that the case could not provide common answers to questions of discrimination and, therefore, the commonality element of class certification was not met.  The Court reached this conclusion finding that the plaintiffs alleged individual acts of discrimination by various supervisors and other employees, rather than a single common policy of discrimination.