Rule 23 And Federal Class Actions Post-Genesis Healthcare

Law360, New York (January 16, 2014, 9:14 PM EST) -- The U.S. Supreme Court’s recent ruling in Genesis Healthcare Corp. v. Symczyk, a seemingly narrow decision on Fair Labor Standards Act collective action litigation, is already beginning to make waves in a much wider pool of cases: Rule 23 class actions.[1]

Genesis Healthcare decided a limited but potentially important issue. The court held that where a defendant’s offer to fully satisfy the named plaintiff’s personal interest in the case mooted her individual claim, the offer also mooted the entire collective action plaintiff intended to bring under...
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