Genesis HealthCare Corp. v. Symczyk

Background

Respondent, a former registered nurse at Pennypack Center in Philadelphia, sued under the FLSA on behalf of herself and "other persons similarly situated," alleging that her employer automatically deducted 30 minutes per shift for unpaid meal breaks even when employees worked. Petitioners answered and served a Rule 68 offer of judgment providing $7,500 plus reasonable fees; the offer lapsed after 10 days because respondent did not accept. Petitioners moved to dismiss for lack of subject-matter jurisdiction; the District Court dismissed, the Third Circuit reversed, and the Supreme Court granted review.

Reasoning

The Court addressed whether a collective FLSA lawsuit can continue when the lone named plaintiff’s individual claim is no longer live. Relying on Article III’s case-or-controversy requirement, the majority assumed the individual claim was moot and held that, in the absence of any additional claimants who had opted in, the named plaintiff lacks a personal stake to represent others, so the suit cannot proceed. The Court distinguished Rule 23 class-action precedents and rejected applying the relation-back doctrine to FLSA collective notices.

Real world impact

As the Court framed it, collective FLSA suits that have only a single named plaintiff may be dismissed if that plaintiff’s individual claim is satisfied and no one else has joined. Defendants may end suits by providing complete relief to the named plaintiff before others opt in. The Court did not resolve the separate question whether an unaccepted Rule 68 offer itself moots an individual claim.

Dissents or concurrances

Justice Kagan, joined by three Justices, dissented, arguing the Court decided a hypothetical based on an assumed mootness, and contended an unaccepted offer cannot moot a claim and that the majority’s ruling is unnecessary.