Genesis Healthcare Corp. v. Symczyk
Facts
Respondent, a former nurse employed by petitioners, sued under the FLSA on behalf of herself and other similarly situated employees, alleging that petitioners automatically deducted 30 minutes per shift for meal breaks even when compensable work was performed during those breaks. Petitioners answered and simultaneously served a Rule 68 offer of judgment for $7,500 in alleged unpaid wages plus reasonable attorneys' fees, costs, and expenses as determined by the court. Respondent did not accept the offer, and no other employees opted into the suit at any point. The lower courts concluded that the offer fully satisfied respondent's individual claim, and the Supreme Court assumed without deciding that her individual claim was therefore moot.
Issue
When the sole plaintiff in an FLSA collective action is assumed to have had her individual claim mooted, but no other employees have opted into the suit, do the collective-action allegations alone keep the case justiciable under Article III?
Rule
A federal case must present a live Article III controversy at all stages, and if an intervening circumstance deprives the plaintiff of a personal stake in the outcome, the action becomes moot. In an FLSA collective action under 29 U.S.C. § 216(b), when no other employee has opted in, the lone plaintiff's suit becomes moot once her individual claim becomes moot, because mere collective-action allegations do not create an independent legal status or preserve a personal interest in representing others.
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