Genesis HealthCare Corp. v. Symczyk

U.S. Supreme Court dismisses FLSA lawsuit after the lone plaintiff was offered complete relief

Term: 2012 Term
Oral Argument Date: Dec 3, 2012
Vote: 5-4
Opinion: Thomas
Questions Presented: 

Whether a case becomes moot, and thus beyond the judicial power of Article III, when the lone plaintiff receives an offer from the defendants to satisfy all of the plaintiff ’s claims.

U.S. Chamber's Position: 

NCLC urged the U.S. Supreme to reverse a Third Circuit decision that held that putative collective actions under the FLSA must continue even though the defendants have offered the only named plaintiff complete relief. In this case, after the petitioners offered the lone respondent complete relief, the court refused to dismiss the matter as moot until the court had a chance to rule on whether the suit could proceed as a collective action. In its amicus brief, NCLC argued that if the Third Circuit's decision is left undisturbed, it will further exacerbate the significant burden already placed on employers who have been subjected to an exponential increase in private FLSA litigation. The Third Circuit’s decision deprives employers of a reasonable means to avoid burdensome FLSA litigation early on, based primarily on the Third Circuit’s policy judgment that further discovery and litigation might motivate others to join a suit being prosecuted by counsel who no longer represents a client with a personal stake in the case’s outcome. In the past decade alone, the number of FLSA suits filed annually has grown by almost 300 percent, affecting nearly every segment of the national economy. Employers that reasonably believe they have complied with the FLSA are often forced to settle unmeritorious collective actions rather than face the risk of catastrophic judgments.

Outcome Content: 

The Supreme Court reversed and remanded the decision of the Third Circuit.  The Court held that because the plaintiff had no personal interest in representing putative unnamed claimants nor any other interest, her suit under the FLSA was properly dismissed for lack of subject matter jurisdiction.

Justices in Majority: 
Justices in Minority: 
Procedural History: 

NCLC amicus brief in support of cert. filed 3/21/12. Cert. granted 6/25/12. NCLC merits brief in support of petitioners filed 9/6/12.  Oral argument held 12/3/12. Decided 4/16/13.