On the heels of its ruling in Shady Grove regarding the inapplicability of state procedural rules in federal court (discussed here), on April 19, 2010, the Supreme Court issued a decision reviving another dismissed class action. In Holster v. Gatco Inc., Case Number 08-1307, the Court granted the appeal petition of an individual seeking to bring a class action in New York federal court under the Telephone Consumer Protection Act (a different law than the one at issue in Shady Grove), and sent the case immediately back to the Second Circuit to consider whether the plaintiff could proceed with a Rule 23 class action in light of Shady Grove. Holster v. Gatco, Inc., 2010 U.S. LEXIS 3118 (U.S. Apr. 19, 2010). This second ruling reinforces the initial interpretation of Shady Grove: namely, that class actions brought in federal court (including those alleging state law claims under statutes such as the New York Labor Law) are governed by Rule 23, and procedural limitations on those class actions contained in the state’s procedural rules may not apply.