Genesis Healthcare Corp. v. Symczyk
United States Supreme Court
569 U.S. ___, 133 S. Ct. 1523 (2013)
Symczyk (plaintiff) was a nurse formerly employed by Genesis Healthcare Corporation (Genesis) (defendant) who sued Genesis in 2009 for alleged violations of the Fair Labor Standards Act (FLSA), 29 U.S.C. § 201 et seq., involving pay deductions for break times that were spent working. Symczyk brought suit on her own behalf and that of “all others similarly situated,” as permitted by the collective-action provisions of the FLSA. 29 U.S.C. § 216(b). Genesis then made an offer of judgment pursuant to Federal Rule of Civil Procedure (FRCP) 68 to settle Symczyk’s individual claim for $7,500 in alleged unpaid wages, plus attorney's fees, costs, and expenses. Per Genesis’s stipulation, the offer was deemed withdrawn after Symczyk did not accept within 10 days. No other claimants joined Symczyk’s collective-action claim. Genesis moved for dismissal for lack of subject matter jurisdiction, arguing that Symczyk’s claim was moot, because Genesis had offered her complete relief. Symczyk argued that Genesis was improperly trying to terminate her individual claim before the court could address the collective-action claim. The district court ruled for Genesis and dismissed the suit. The United States Court of Appeals for the Third Circuit agreed the individual claim was moot, but reversed, finding that Genesis’s attempt to “pick off” the individual claim interfered with the collective-action process. Symczyk did not challenge the ruling that her own claim was moot on appeal. The United States Supreme Court granted certiorari on the issue of whether the collective-action claim was justiciable.
Rule of Law
Holding and Reasoning (Thomas, J.)
Dissent (Kagan, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 175,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.