16 April 2013
Law in Plain English: Genesis HealthCare Corp. v. Symczyk
This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.
Symczyk was an employee of a nursing home owned by Genesis HealthCare. Their policy was to deduct 30 minutes of pay for a lunch break, but Symczyk and others often worked through their breaks. Symczyk brought a "collective action" (similar to, but not, a class action) lawsuit under the Fair Labor Standards Act (FLSA), alleging that she and others were entitled to be paid for the time they worked through her lunch breaks. Genesis offered to pay $7,500 for unpaid wages (which was everything that Symczyk had asked for), but she did not respond. The question before the Court was whether the case became moot, and beyond the judicial power of Article III, when the lone plaintiff received an offer from the defendants to satisfy all of the plaintiff's claims. In a 5-4 decision, the Supreme Court ruled that once Genesis has offered to pay everything she had asked for, she no longer had any personal interest in representing putative, unnamed claimants, nor any other continuing interest that would preserve her suit from mootness. As a result, her suit was appropriately dismissed by the Third Circuit. The practical impact of this decision on a larger scale is that when a defendant offers everything the plaintiff asks for, there may not be anything left for the courts to decide (although the Court didn't technically rule on this issue).