Genesis HealthCare Corp. v. Symczyk

Summary

The Supreme Court held that an FLSA collective action became moot when the named plaintiff’s individual claim was rendered moot and no other employees had opted into the action. The Court concluded that the plaintiff had no personal interest in representing unnamed claimants and that FLSA conditional certification does not create a separate legal entity comparable to a Rule 23 class. The judgment of the Third Circuit was reversed.

Holdings

1. The Court did not decide whether an unaccepted Rule 68 offer that fully satisfies a plaintiff's claim is sufficient to render the claim moot; it assumed that proposition because respondent conceded it below and did not properly preserve the issue for review.
2. Once the named plaintiff's individual claim became moot, the FLSA action also became moot because the plaintiff had no personal interest in representing other employees and no other claimant had opted into the action.
3. Rule 23 doctrines concerning certified classes and relation back do not preserve an FLSA collective action when the named plaintiff's claim becomes moot before conditional certification and no other employee has opted in.
4. The inherently transitory relation-back doctrine does not apply merely because a defendant uses Rule 68 offers to pick off a named plaintiff in an FLSA damages action.
5. Deposit Guaranty National Bank v. Roper does not preserve the FLSA action because respondent had no continuing economic interest in shifting attorney fees or costs and the significance of Rule 23 certification does not transfer to FLSA conditional certification.

Questions Presented

1. Whether an FLSA collective action remains justiciable when the lone named plaintiff's individual claim is assumed to have become moot before conditional certification and before any other claimant opted into the action.
2. Whether Rule 23 class-action doctrines concerning certified classes, relation back, inherently transitory claims, and ongoing economic interests preserve an FLSA collective action under those circumstances.

Disposition

reversed