Hepler v. Abercrombie & Fitch Co.

Summary

The court granted defendants’ motion to dismiss an FLSA collective action as moot after defendants made Rule 68 offers exceeding the maximum recovery available to the named plaintiff and one opt-in plaintiff. The court held that the plaintiffs were not entitled to the requested injunctive or declaratory relief under the FLSA and declined supplemental jurisdiction over the NYLL claims, dismissing those claims without prejudice.

Holdings

1. A Rule 68 offer providing full recovery of the amounts available under the FLSA renders the named plaintiff's FLSA claim moot when the offer is rejected or expires.
2. The requested declaratory and injunctive relief did not prevent mootness because the FLSA does not authorize these plaintiffs to obtain that relief for the alleged minimum-wage and overtime violations.
3. Later joinder of opt-in plaintiffs and a motion for conditional certification filed after the Rule 68 offers did not prevent dismissal of the moot FLSA claim or revive it.
4. The court declined to exercise supplemental jurisdiction over the New York Labor Law claims after dismissing the sole federal claim and dismissed those claims without prejudice.

Questions Presented

1. Whether defendants' Rule 68 offers of judgment for more than the maximum recoverable FLSA amounts rendered Hepler's and the opt-in plaintiff's FLSA claims moot.
2. Whether the requested declaratory and injunctive relief prevented the FLSA claim from becoming moot.
3. Whether later-joined opt-in plaintiffs or a post-offer motion for conditional certification prevented dismissal of the moot FLSA claim.
4. Whether the court should exercise supplemental jurisdiction over the New York Labor Law claims after dismissing the sole federal claim.

Disposition

dismissed