Genesis Healthcare v. Symczyk (2012)
- Docket
- 11-1059
- Decided
- 2012-01-01
Summary
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? Conclusion: Yes. Justice Clarence Thomas delivered the opinion of the 5-4 majority. The Supreme Court held that established mootness principles determined that, in cases that lack other claimants, the suit on behalf of other "similarly situated" employees becomes moot when the individual claim does. Since Symczyk no longer had a personal interest and was not representing the interests of a broader class, the case was properly dismissed. In her dissenting opinion, Justice Elena Kagan argued that the premise on which the majority's decision is based—that Symczyk's individual claim is moot—is incorrect. She wrote that, because Symczyk rejected the settlement offer, she retained her personal interest in the case, and there was no reason to consider her claim moot. Justice Ruth Bader Ginsburg, Justice Stephen G. Breyer, and Justice Sonia Sotomayor joined in the dissent.