Genesis HealthCare Corp. v. Symczyk

Whether Article III’s Case or Controversy Clause moots an action when the plaintiff receives an offer that satisfies all of plaintiff's claims.

Respondent, who worked for Petitioner as a Registered Nurse, filed suit under the Fair Labor Standards Act (FLSA), 29 U.S.C. §§ 207 and 216(b), on behalf of herself and all similarly situated individuals, claiming that Petitioner’s policy of automatically deducting for a meal break, regardless of whether or not the employee performed work during the break, violated the FLSA. Petitioner made an Fed. R. Civ. Pro. Rule 68 motion for judgment and offered Respondent the full amount of her complaint plus attorney's fees and costs. Respondent did not respond to the offer within the fourteen days permitted by Rule 68, and Petitioner filed a motion to dismiss, claiming the court lacked subject matter jurisdiction given that the only named plaintiff to the suit had rejected the offer and therefore no longer had a cognizable interest in the outcome of the action. The District Court dismissed Respondent’s FLSA claim, finding that Petitioner’s Rule 68 motion mooted the collective action.

The Court of Appeals for the Third District reversed, reasoning that although Respondent no longer had an interest in the case, that there may be other members of the class who had yet to come forward and that allowing a defendant’s “tender of judgment to pick off multiple plaintiffs” would “frustrate the objectives of class actions.”

On appeal Petitioner argues that permitting the litigation to continue despite the lack of an adverse party is a violation of Article III's “limitation of the judicial power to actual Cases and Controversies.”