In the case of Campbell-Ewald Co. v. Gomez, the Supreme Court ruled that a defendant cannot terminate a class action lawsuit by offering to satisfy the plaintiff's individual claim before they certify a class. The dispute began when Jose Gomez received an unsolicited text message from Campbell-Ewald Company, violating the Telephone Consumer Protection Act (TCPA). Before Gomez could file for class certification, Campbell offered to settle his individual claim but did not extend this offer to potential class members. When Gomez refused this settlement offer and proceeded with his suit, Campbell argued that their offer mooted Gomez’s entire action because it provided him complete relief on his personal TCPA claim. However, in 2016, Justice Ruth Bader Ginsburg delivered the opinion of a 6-3 court stating that an unaccepted settlement offer does not nullify a case under Article III.

In the dissenting opinion for Campbell-Ewald Co. v. Gomez, Chief Justice Roberts, joined by Justices Scalia and Alito, argued that the case should have been dismissed after Campbell offered to fully satisfy Gomez's claims. They contended that an unaccepted settlement offer or offer of judgment does not moot a plaintiff’s case but if it offers complete relief on the plaintiff's claim then there is no dispute left to resolve and thus no need for further litigation. The dissenters also disagreed with the majority's reliance on contract law principles in its analysis of whether an unaccepted offer can moot a claim under Article III of Constitution, arguing instead that this issue should be resolved based on traditional principles of federal jurisdiction.