Mooting the Mootness Issue as Moot?: Symczyk’s Impact on FLSA Litigation in Florida and Beyond

There were a lot of lawsuits about wages and hours under a law called the Fair Labor Standards Act. The number of cases went way up because the law says that the winning side gets their lawyer fees paid, it’s strict about following the rules, and it lets one employee sue for a group of people. To stop these lawsuits, some companies offer to settle with the main person suing, then argue that the case is over and no one else can join in. This makes it harder for other employees to get in on the lawsuit. People disagree on whether this is fair under the law. The U.S. Supreme Court recently made a ruling in Symczyk v. Genesis Healthcare Corporation that affects how lawsuits can be brought against companies. The ruling has practical implications for both people suing a company (plaintiffs) and the company being sued (defendants). The background of the case involves a law that governs how employees are paid, and the Court’s ruling could make it harder for employees to bring a lawsuit together. This could make it harder for employees to fight for their rights in court. The FLSA was passed in 1938 to help low-wage workers. Originally, employees could file a collective action on behalf of all similarly situated workers. But in 1947, Congress changed the law so that employees had to opt-in to join a collective action. If a court agrees that the workers are similarly situated, they can send notice to other potential plaintiffs to join the case.

In a class action under Rule 23, a representative plaintiff must ask the court to certify the class before the case can proceed. The named plaintiff has a personal stake in this certification.

A defendant can make an offer of judgment under Rule 68 that covers everything the plaintiff could win at trial. If the plaintiff accepts, their claim could be dismissed, and the case could end.

Sometimes, defendants make this offer to the named plaintiff in an FLSA case before other workers have a chance to join. Some courts have concerns that this can prevent collective actions from moving forward. This issue has led to a split in authority, and the Supreme Court is reviewing a case about it. Laura Symczyk filed a lawsuit against her former employer for not getting paid for working during meal breaks. Her employer offered her money to settle the case, but she didn’t respond. The court said the case was over because of the offer, but Laura appealed. The appeals court said Laura should have been able to ask other employees to join her case before it was dismissed. The case is still ongoing. The Supreme Court didn’t directly answer whether a Rule 68 offer of judgment can end a plaintiff’s claims. They said the plaintiff didn’t challenge the lower court’s ruling, so they upheld it without further analysis. The dissenting opinion disagreed with this decision. The Court did say that if a plaintiff’s claim is mooted, the whole lawsuit becomes moot. They also said that conditional certification under §216(b) won’t save a previously mooted case. The Court looked at whether a lawsuit can continue if the problem is only temporary, and said it can’t for this type of case. The majority also said that the rules for this type of case are different from the rules for regular class action lawsuits. Justice Kagan disagreed with the majority, saying they didn’t address the main question and their decision doesn’t help much. Justice Kagan explained that an unaccepted offer cannot make a court case go away and that the majority’s decision doesn’t help anyone. The majority could have directly answered the real question at hand, but their decision does provide some guidance for courts in Florida to resolve similar issues. The Middle District and other federal courts in Florida have debated whether a defendant’s offer to fully settle a plaintiff’s claim should end the case. The Supreme Court says it can, but some courts still have concerns. Now, the big issue in these cases will be figuring out exactly how much money the plaintiff should get. Some courts are using special questions to help with this, and there may be more focus on the rules that require parties to say how much money they want and how they calculated that amount. The rule states that when someone sues for FLSA (Fair Labor Standards Act) violations, they must show how they calculated the amount of money they are claiming as damages. Courts in Florida have said that this means they have to provide a specific amount and how they came up with it for their economic damages. This will be important in FLSA cases because defendants will use this information to make settlement offers and potentially end the case. The Supreme Court didn’t directly address the issue of whether a settlement offer can end a case, but their decision means that these offers might become more important. This will likely mean that there will be more focus on calculating economic damages in these cases. These are references to court cases and legal rules about how class action lawsuits work. They discuss things like inconsistencies in labor regulations, the process for certifying a class action, and the rights of named plaintiffs in a lawsuit. Some of the cases mentioned include Long Island Care at Home, Ltd. v. Coke, Hoffman-La Roche, Inc. v. Sperling, and Morgan v. Family Dollar Stores, Inc. These cases and rules are important for understanding how class action lawsuits are decided in court. This is about a case where a woman named Laura Symczyk sued her employer, Genesis HealthCare Corp., for not paying her and her co-workers properly. The employer offered to settle the case before it went to trial, but Laura didn’t accept the offer. The court decided to dismiss the case because they said it was no longer a real legal issue. Laura tried to appeal the decision, but the court said she couldn’t because she didn’t accept the offer. She asked the highest court in the country to review her case, but they decided not to do it. Some judges didn’t agree with the decision and thought Laura should have been allowed to appeal. This is an article by a lawyer named J. Evan Gibbs about legal cases in Florida. It talks about how offers of full relief can make a claim moot, and it gives examples of different court cases. The article also mentions the rules of civil procedure and where the author went to law school. The article was written for a section of the Florida Bar association.

Source: https://www.floridabar.org/the-florida-bar-journal/mooting-the-mootness-issue-as-moot-symczyks-impact-on-flsa-litigation-in-florida-and-beyond/