Supreme Court rules narrowly on mootness of a class action claim

[JURIST] The US Supreme Court [official website] ruled 5-4 Tuesday in Genesis HealthCare Corp. v. Symczyk [opinion, PDF; JURIST report] that the claim was moot [Cornell LII backgrounder] because respondent "had no personal interest in representing putative, unnamed claimants, nor any other continuing interest that would preserve her suit from mootness." The original question presented concerned whether an issue at the center of a lawsuit is moot if an offer is made to settle with the potential plaintiff that fully covers the damages, whether or not the plaintiff accepts. The court did not rule on this question, but only settled the claim at hand, ruling that the original plaintiff, Laura Symczyk, and her colleagues, could no longer pursue class action status. Justice Clarence Thomas presented the opinion of the court:

In this case, respondent's complaint requested statutory damages. Unlike claims for injunctive relief challenging ongoing conduct, a claim for damages cannot evade review; it remains live until it is settled, judicially resolved, or barred by a statute of limitations. Nor can a defendant's attempt to obtain settlement insulate such a claim from review, for a full settlement offer addresses plaintiff's alleged harm by making the plaintiff whole. While settlement may have the collateral effect of foreclosing unjoined claimants from having their rights vindicated in respondent's suit, such putative plaintiffs remain free to vindicate their rights in their own suits. They are no less able to have their claims settled or adjudicated following respondent's suit than if her suit had never been filed at all.
The court reversed [opinion, PDF] the US Court of Appeals for the Third Circuit.

Justice Elena Kagan authored the dissent, criticizing the majority for not reaching the issue at question, calling the decision "the most one-off of one-offs." "The Court today resolves an imaginary question, based on a mistake the courts below made about this case and others like it. The issue here, the majority tells us, is whether a 'collective action' brought under the Fair Labor Standards Act of 1938 (FLSA) 'is justiciable when the lone plaintiff's individual claim becomes moot.' Embedded within that question is a crucial premise: that the individual claim has become moot, as the lower courts held and the majority assumes without deciding. But what if that premise is bogus? What if the plaintiff's individual claim here never became moot?" Kagan further declared that "the Court chose to address an issue predicated on that misconception, in a way that aids no one, now or ever."

 

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