Offers in group wage lawsuits
Genesis HealthCare v. Symczyk
In brief
The Supreme Court said Symczyk's suit should be thrown out, but left unanswered whether Genesis's full offer itself made her individual claim no longer live.
- Where it stands
- Decided
Decided 5-4 · April 16, 2013 · Opinion by Justice Thomas
- What it’s about
- Laura Symczyk sued Genesis HealthCare over meal-break pay for herself and co-workers; Genesis offered to fully resolve her claim before others joined.
- Who it affects
- Symczyk's suit was to be thrown out, but the Court did not decide whether a full offer alone ends a group lawsuit under the Fair Labor Standards Act.
Summary: written with AI from the case record.
What it's about
The Supreme Court overturned the appeals court: without deciding whether her claim was moot (no longer a live dispute), it found she had no stake in representing others or other interest keeping the suit alive.
Symczyk brought a group lawsuit under the Fair Labor Standards Act, seeking to include other employees she said were in similar situations.
Question presented
Does an offer of judgment providing full relief to a single plaintiff extinguish a collective action FLSA suit when no other parties had yet joined the suit?
What the Court decided
Holding
Because respondent had no personal interest in representing putative, unnamed claimants, nor any other continuing interest that would preserve her suit from mootness, her suit was appropriately dismissed for lack of subject-matter jurisdiction. 656 F. 3d 189, reversed.
- Result
- Reversed
The Court's reasoning
The Court assumed, without deciding, that Symczyk's individual claim had become moot (no longer a live dispute). It said she had no personal stake in representing unnamed workers and no other continuing interest to keep her suit alive.
The vote
From the opinions
“The Court today resolves an imaginary question, based on a mistake the courts below made about this case and others like it.”
What's next
Symczyk's suit should be thrown out under the Court's ruling. The Court left open whether Genesis's offer ended her individual claim.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
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Audio Recording added: Oral Arguments - Symczyk
Opinion added: Symczyk
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.