In a 6-3 opinion, the United States Supreme Court held yesterday that a defendant’s unaccepted Rule 68 offer of judgment for complete relief does not moot a case. See Campbell-Ewald Co. v. Gomez, 577 U.S. ___ (2016). Justice Bader Ginsburg, writing for the 6-3 majority, explained that “[u]nder basic principles of contract law,” an offer without acceptance is a legal nullity. Therefore, the Court reasoned, if a plaintiff does not accept a defendant’s mid-case settlement offer, the plaintiff gains no entitlement to relief, and “the parties remain[] adverse; both retain[] the same stake in the litigation they had at the outset.”

In so ruling, the Court addressed a question left open by its 2013 decision in Genesis HealthCare Corp. v. Symczyk, 569 U.S. ___; 133 S. Ct. 1523 (2013). In Genesis HealthCare, the majority declined to decide whether an unaccepted offer of complete relief mooted an individual’s claim because the plaintiff failed to preserve that argument. Even though defendant’s Rule 68 offer in Genesis HealthCare (whose lead counsel was Greenberg Traurig) was not accepted, Plaintiff did not argue that her failure to accept the Rule 68 offer prevented dismissal of her individual claim. Rather, she conceded that the offer mooted her individual claim and instead insisted that her case was not subject to dismissal because she brought her claim as a collective action on behalf of a group, and the Company’s offer of judgment provided no relief for that group. Unlike Mr. Gomez, therefore, the plaintiff in Genesis Healthcare never denied that the offer of judgment mooted her individual claim, and thus the majority did not reach the question. Justice Kagan wrote a critical dissent in Genesis HealthCare, explaining that she would have reached the mootness question, and stating that “an unaccepted offer of judgment cannot moot a case.”

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Photo of Christiana L. Signs Christiana L. Signs

Ms. Signs’ practice concerns complex employment matters, focusing primarily on class and collective wage and hour, discrimination and Fair Credit Reporting Act litigation. She has experience pursuing appellate issues related to employment-related class and collective action litigation, having co-authored several principle and amicus…

Ms. Signs’ practice concerns complex employment matters, focusing primarily on class and collective wage and hour, discrimination and Fair Credit Reporting Act litigation. She has experience pursuing appellate issues related to employment-related class and collective action litigation, having co-authored several principle and amicus briefs in cutting-edge class action employment cases. Ms. Signs routinely advises employers on an array of labor and employment compliance matters. Those include Fair Credit Reporting Act and state background check issues; best practices vis-à-vis employment dispute resolution programs; and drafting, enforcing and negotiating restrictive covenants. A member of the firmwide Business Continuity Amid COVID-19 Team, she advises her clients regarding telecommuting and the Families First Coronavirus Response Act.

Photo of James N. Boudreau James N. Boudreau

James N. Boudreau is Co-Chair of the Global Labor & Employment Practice and the Labor & Employment Practice’s Collective & Systemic Employment Litigation group. He represents management in class action and complex employment litigation and devotes the majority of his practice to managing…

James N. Boudreau is Co-Chair of the Global Labor & Employment Practice and the Labor & Employment Practice’s Collective & Systemic Employment Litigation group. He represents management in class action and complex employment litigation and devotes the majority of his practice to managing teams of attorneys and paralegals in nationwide class and collective actions from receipt of the complaint through discovery, class certification and trial. He is considered a thought leader in class-based employment litigation and has been listed by Human Resource Executive magazine as one of “The Nation’s Most Powerful Employment Lawyers – Top 100,” each year since 2013.  He was also selected as one of five Law360 “MVP – Labor and Employment,” for 2012, for his cutting-edge work representing employers in class and collective actions.