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Genesis Healthcare Corp. v. Symcyzk

Summarized by: 

Date Filed: April 16, 2013
Case #: 11-1059
Thomas, J., delivered the opinion of the Court,in which Roberts, C. J., and Scalia, Kennedy, and Alito, JJ., joined. Kagan, J., filed a dissenting opinion, in which Ginsburg, Breyer, and Sotomayor, JJ., joined.
Full Text Opinion: http://www.supremecourt.gov/opinions/12pdf/11-1059_5ifl.pdf

Civil Procedure: A collective action to recover damages is not justiciable if the sole plaintiff's individual claim becomes moot.

Respondent brought a claim for lost wages under the Fair Labor Standards Act on behalf of herself, as well as a collective action on behalf of other “persons similarly situated.”  Petitioner responded by serving Respondent with an offer of judgment under Federal Rule of Civil Procedure 68, which Respondent did not accept. The district court found that no others joined Respondent’s suit and that Petitioner’s offer of judgment fully satisfied Respondent’s claim. Therefore, the court concluded, Respondent’s claim was moot and the court dismissed the case for lack of subject matter jurisdiction.

The United States Court of Appeals for the Third Circuit reversed, concluding that while Respondent’s individual claim was moot, her collective action was not.  The court reasoned that allowing defendants to “pick off” individually named plaintiffs before a collective action could be certified would frustrate the collective action process.  The court remanded the case for “conditional certification.”

The Supreme Court reversed. The Court applied “well settled mootness principles” and held that respondent’s collective action was properly dismissed for lack of subject matter jurisdiction because Respondent no longer had an individual interest in representing putative unnamed plaintiffs.