This Jackson Lewis LLP memorandum discusses the California Court of Appeal's February 6, 2012 decision in Duran v. U.S. Bank National Association. In this class action for alleged unpaid overtime, the trial court certified a class of 260 employees and selected a random witness group of 20 plaintiffs to testify at trial. The appellate court held that the trial court's use of representative sampling in place of trial testimony unfairly prevented the employer from defending itself. The employer was therefore denied due process. The court reversed the judgment and ordered the class to be decertified. This is the first California decision to analyze in detail an employer's due process rights in a class action.