A bitterly divided United States Supreme Court last week added even more height to the barriers facing plaintiffs who seek to certify their claims as class actions. In Comcast Corp. v. Behrend, No. 11-864, a 5-4 decision penned by Justice Antonin Scalia, the Court held that a district court improperly certified a mammoth class action covering more than two million current and former subscribers of Comcast who claimed to have paid inflated cable bills based upon Comcast’s violation of federal antitrust laws. The decision is particularly notable for its holding that plaintiffs seeking to certify class actions for money …