A divided panel of the Sixth Circuit followed the Allison decision, reversing a (b)(2) certification of gender discrimination claims brought by prison guards. It appears from the decision that, in addition to class-wide injunctive relief, the named plaintiffs sought damages for themselves but not on behalf of the class. Rejecting certification, the court suggested that plaintiffs in Title VII cases have the choice of proceeding under Rule 23(b)(3) in actions for money damages or under Rule 23(b)(2) in actions for declaratory or injunctive relief alone or in conjunction with compensatory and punitive damages that inure to the group benefit of the class as a whole. Judge Keith, dissenting, urged the court to follow the Second Circuit’s decision in Robinson, suggesting the possible use of a “hybrid” (b)(2)/(b)(3) certification, wherein liability and damages portions of the trial are bi-furcated, and the plaintiffs are afforded opt-out rights with respect to their claims for monetary damages. Reed v. Ohio Dept. of Rehab. & Corrections, 435 F.3d 639 (6th Cir. 2006).