Genesis Healthcare Corporation v. Symczyk

569 U.S. 66 (2013)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

The Fair Labor Standards Act of 1938 (FLSA) establishes federal minimum-wage, maximum-hour, and overtime guarantees that cannot be modified by contract. Section 216(b), gives employees the right to bring a private cause of action on their own behalf and on behalf of “other employees similarly situated” for specified violations of the FLSA. P, who was formerly employed by D as a registered nurse filed a complaint on behalf of herself and “all other persons similarly situated.” P alleged that D violated the FLSA by automatically deducting 30 minutes of time worked per shift for meal breaks for certain employees, even when the employees performed compensable work during those breaks. P remained the sole plaintiff throughout these proceedings. P sought statutory damages for the alleged violations. D answered the complaint and simultaneously served upon P an offer of judgment under Rule 68. The offer included $7,500 for alleged unpaid wages, in addition to “such reasonable attorneys’ fees, costs, and expenses . . . as the Court may determine.” If P did not accept the offer within 10 days after service, the offer would be deemed withdrawn. P failed to respond. D filed a motion to dismiss for lack of subject-matter jurisdiction. D argued that because it offered P complete relief on her individual damages claim, she no longer possessed a personal stake in the outcome of the suit, rendering the action moot. P objected, arguing that D was inappropriately attempting to “pick off” the named plaintiff before the collective-action process could unfold. No other individuals had joined P’s suit. The court found that the Rule 68 offer of judgment fully satisfied her individual claim. It concluded that D's Rule 68 offer of judgment mooted P’s suit, which it dismissed for lack of subject-matter jurisdiction. The Court of Appeals reversed holding that P's collective action was not moot and remanded for conditional certification. D appealed.