Genesis Healthcare v. Symczyk

PETITIONER: Genesis Healthcare Corp., et al.
RESPONDENT: Laura Symczyk
LOCATION: Genesis HealthCare Corporate Headquarters

DOCKET NO.: 11-1059
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Third Circuit

CITATION: 569 US (2013)
GRANTED: Jun 25, 2012
ARGUED: Dec 03, 2012
DECIDED: Apr 16, 2013

ADVOCATES:
Anthony A. Yang - Assistant to the Solicitor General, Department of Justice, for the United States as amicus curiae supporting the respondent
Neal Kumar Katyal - for the respondent
Ronald Mann - for the petitioners

Facts of the case

Genesis Healthcare Corporation ("Genesis") employed Laura Symczyk as a registered nurse between April 2007 and December 2007. During her employment, Genesis implemented a policy that automatically deducted pay for employees' meal breaks whether or not they worked during those breaks. This prompted Symczyk to file a collective action on behalf of herself and all similarly situated individuals, alleging violation of the Fair Labor Standards Act ("FLSA"). In February 2010, Genesis offered to pay all of Symczyk's unpaid wages and attorney's fees. Symczyk did not respond to the offer. Genesis filed a motion to dismiss for lack of subject matter jurisdiction, claiming that Symczyk no longer had a real interest in the outcome of the action since they offered her full relief.

Since Genesis made an offer of judgment and no one had yet joined Symczyk's collective action, the District Court dismissed the case. Symczyk appealed, and the U.S. Court of Appeals for the Third Circuit reversed and remanded. The Third Circuit held that a full offer of relief does not cause an FLSA collective action suit to be dismissed.

Question

Does an offer of judgment providing full relief to a single plaintiff extinguish a collective action FLSA suit when no other parties had yet joined the suit?

Media for Genesis Healthcare v. Symczyk

Audio Transcription for Oral Argument - December 03, 2012 in Genesis Healthcare v. Symczyk

Audio Transcription for Opinion Announcement - April 16, 2013 in Genesis Healthcare v. Symczyk

John G. Roberts, Jr.:

Justice Thomas has our opinion this morning in case 11-1059, Genesis HealthCare versus Symczyk.

Clarence Thomas:

This case comes to us on a writ of certiorari to the United States Court of Appeals for the Third Circuit and I don't have good news for them either.

The Fair Labor Standards Act of 1938, FLSA, provides that an employee may bring an action to recover damages for specified violations on behalf of himself and other similarly situated employees.

In this case, the respondent who worked as a nurse filed a suit against her former employers alleging that they violated the FLSA by automatically deducting 30 minutes per shift for meals -- for meal breaks even when employees worked during those periods.

Respondent claim she was bringing suit for herself and on behalf of all other persons similarly situated, but she remained the only plaintiff throughout the litigation.

After respondent filed her suit, petitioners offered her complete monitory relief on her individual claim as well as caused in attorney's fees.

Respondent rejected the offer.

The District Court then dismissed the suit concluding that petitioner's offer rendered the suit moot because it would have given the respondent everything she requested as an individual plaintiff.

The Third Circuit reversed.

The Court concluded that even though petitioner's offer satisfied respondent's individual claim, the action was not moot because respondent also filed a complaint on behalf of similarly situated employees.

The Court believed that this fact entitled respondent to continue the collective action suit in District Court.

In an opinion filed with the clerk today, we reverse the judgment of the Third Circuit.

The constitution provides that federal courts only have jurisdiction over "Cases and Controversies.

This language requires plaintiff to show that they had a personal -- plaintiffs to show that they have a personal stake in the outcome of the litigation at all times.

Otherwise, a suit becomes moot and must be dismissed.

In this case, respondent did dispute -- the District Court's didn't -- did not dispute the District Court's conclusion that the petitioner's offer fully satisfied her individual claim.

In light of this concession, a straightforward application of mootness principles confirms that the action was appropriately dismissed.

Respondent offers a number of reasons why she believes she still has a personal stake in the litigation.

We do not find any of them persuasive.

First, the respondent argues that she has a statutory interest in representing other employees under the FLSA.

However, nothing in the FLSA gives a right when the named plaintiff is the only plaintiff in the suit and her individual claim is fully satisfied.

Second, respondent relies on several Rule 23 class-action cases suggesting that a name plaintiff may remain in a suit even after his claim is moot, if the claim is, inherently transitory.

These cases are irrelevant, however, because damages claims are not inherently transitory.

Damages claims remain viable until they are settled, judicially resolved or barred by statute of limitations.

Third, respondent argues that the purposes of the FLSAs collective action provisions could be frustrated by strategic settlement offers designed to pick off named plaintiffs before a collective action can run its course.

But this policy concern cannot overcome the constitutional requirement that the named plaintiff maintain a personal stake throughout the action.

Because respondent cannot show that she maintained a personal stake in the suit and once her individual claim became moot, we conclude that the District Court was correct to dismiss the case for lack of subject matter jurisdiction.

Justice Kagan has filed a dissenting opinion in which Justices Ginsburg, Breyer, and Sotomayor joined.