Supreme Court: FLSA Collective Action Properly Dismissed after Plaintiff's Individual Claims Are Rendered Moot | Practical Law
In Genesis Healthcare Corp. v. Symczyk, the US Supreme Court held in a 5 to 4 decision that a Fair Labor Standards Act (FLSA) collective action was properly dismissed for lack of subject matter jurisdiction when the plaintiff's individual claims became moot, leaving her with no personal interest in representing other unnamed, putative claimants in the action. The decision highlights, but does not resolve, a circuit court split on the question of whether a plaintiff's rejection of a Federal Rule of Civil Procedure (FRCP) 68 offer of judgment that fully satisfies her claims renders the claims moot.