In the case of Genesis Healthcare Corporation v. Laura Symczyk, the U.S. Supreme Court ruled in favor of Genesis Healthcare Corp., stating that a collective action under the Fair Labor Standards Act (FLSA) was moot when the lone plaintiff's individual claim became moot due to an unaccepted offer to satisfy her claim from defendants. Symczyk, a registered nurse at Pennypack Center in Philadelphia, alleged that Genesis automatically deducted meal breaks from employees' pay regardless if they performed compensable work during those breaks and sought relief on behalf of herself and "all others similarly situated." However, before any other potential plaintiffs joined her suit, Genesis offered to settle Symczyk’s personal claims which she did not accept but also failed to dispute within court-specified time limits. The court held that since no other individuals had joined and her own personal interest in litigation was extinguished by defendant's offer for settlement; there were no remaining parties with a live controversy necessary for Article III standing.

In the dissenting opinion for Genesis Healthcare Corporation v. Laura Symczyk, Justice Elena Kagan argued that the case should have been dismissed as improvidently granted. She contended that Symczyk's individual claim was not moot because she had not accepted Genesis' offer to settle her claims and therefore there remained a live controversy between the parties. Furthermore, even if Symczyk's individual claim were moot, it would not necessarily render moot her collective action under Fair Labor Standards Act (FLSA). According to Justice Kagan, FLSA’s collective-action provision has an inherently trans-subjective structure such that one plaintiff can bring a lawsuit on behalf of other similarly situated individuals who retain their interest in pursuing litigation even when named plaintiff’s personal interests become moot. Therefore, she disagreed with majority’s view which allowed employers to use strategic settlement offers to “pick off” plaintiffs thereby derailing potential class actions before they could proceed.