Genesis HealthCare Corp. v. Symczyk
133 S. Ct. 1523
| SCOTUS | 2013Background
- Respondent Symczyk, a former nurse, sued Genesis under the FLSA on behalf of herself and others similarly situated.
- Genesis served an unaccepted Rule 68 offer of judgment to satisfy Symczyk's individual claim, including unpaid wages and costs.
- Symczyk did not respond within the deadline; the District Court dismissed for lack of subject-matter jurisdiction as moot.
- The Third Circuit reversed, holding the individual claim moot but the collective-action claim viable, suggesting conditional certification could relate back to the filing date.
- The Supreme Court assumed arguendo that the unaccepted offer mooted Symczyk’s individual claim but resolved the case on broader mootness grounds.
- The Court held Symczyk’s suit was properly dismissed for lack of a personal stake in representing unnamed claimants, ending the action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does an unaccepted Rule 68 offer moot the plaintiff's individual FLSA claim? | Symczyk: offer moots her claim; she loses standing. | Offer fully satisfies individual relief and can moot the claim. | Court assumes mootness, not deciding. |
| Can a collective action under the FLSA proceed after the named plaintiff's individual claim is moot? | Collective action remains viable to recover for others. | MOOTNESS of the individual claims defeats the action absent a live stake. | Suit dismissed for lack of subject-matter jurisdiction; no personal stake. |
| Is the relation-back doctrine available to save the collective action in this FLSA context? | Geraghty/Sosna logic could preserve the class via relation back. | Relation back not applicable in FLSA with conditional certification lacking independent status. | Relation back not applicable; ultimately not resolved in the majority opinion. |
| Are Sosna and Geraghty inapt precedents to apply to FLSA collective actions? | Those lines support continuance of a live controversy. | They are inapplicable due to Rule 23 vs. §216(b) differences. | Inapplicable; does not save the action. |
Key Cases Cited
- Sosna v. Iowa, 419 U.S. 393 (1975) (class action live controversy after mootness of named plaintiff)
- United States Parole Comm’n v. Geraghty, 445 U.S. 388 (1980) (relation back for denials of class certification)
- County of Riverside v. McLaughlin, 500 U.S. 44 (1991) (inherently transitory class-action relation-back doctrine)
- Deposit Guaranty Nat. Bank v. Roper, 445 U.S. 326 (1980) (illustrates certification-related interests in class actions)
- Hoffmann-La Roche Inc. v. Sperling, 493 U.S. 165 (1989) (collective action under FLSA; conditional certification; notice to employees)
- Lindahl v. Hoffmann-La Roche, N/A (N/A) (not included; placeholder avoided)