Genesis Healthcare Corp. v. Symczyk
United States Supreme Court
569 U.S. ___, 133 S. Ct. 1523 (2013)
Symczyk (plaintiff), a nurse, sued Genesis Healthcare (defendant) under the FLSA on her own behalf and that of similarly situated employees over allegedly unlawful pay deductions; Genesis made a Rule 68 offer of judgment covering her full individual claim, which she did not accept within 10 days, and no other employees had joined the collective action. The district court dismissed for lack of jurisdiction, finding her individual claim moot; the Third Circuit agreed her individual claim was moot but held the case could still proceed because Genesis's attempt to "pick off" her claim improperly interfered with the collective-action process, and Genesis sought Supreme Court review, with Symczyk not contesting the mootness finding on her own claim.
Whether a collective-action claim under the Fair Labor Standards Act remains justiciable after the lone plaintiff's individual claim becomes moot.