Genesis Healthcare Corp. v. Symczyk

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 Per Genesis’s stipulation, the offer was deemed withdrawn after Symczyk did not accept within 10 days.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.