Supreme Court Holds That Unaccepted, Full-Value Rule 68 Offer of Judgment Deprives Court of Subject Matter Jurisdiction Over FLSA Collective Action
In an case with broad implications for federal class action practice, the U.S. Supreme Court held today, in a 5-4 opinion, that an FLSA collective action was properly dismissed for lack of subject matter jurisdiction, where the lead plaintiff did not accept the employer’s full-value offer of judgment under Federal Rule of Civil Procedure 68. Genesis Healthcare Corp., et al. v. Symczyk, No. 11-1059, 569 U.S. __ (April 16, 2013).
Justice Thomas, writing for the 5-4 majority, concluded that:
Reaching the question on which we granted certiorari,we conclude that respondent has no personal interest in representing putative, unnamed claimants, nor any other continuing interest that would preserve her suit from mootness. Respondent’s suit was, therefore, appropriately dismissed for lack of subject-matter jurisdiction.
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