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ARTICLE · 20 JANUARY 2016

Supreme Court Decision Alert - January 20, 2016

Mayer Brown
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Today, the Supreme Court issued two decisions, described below, of interest to the business communi

United StatesLitigation, Mediation & Arbitration
Brian Netter
Brian Netter
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Today, the Supreme Court issued two decisions, described below, of interest to the business community.

  • Class Actions And Federal Jurisdiction—Effect of Unaccepted Offers of Judgment on Mootness
  • Employee Retirement Income Security Act—Enforcement of Plan Subrogation Clauses

Class Actions And Federal Jurisdiction—Effect of Unaccepted Offers of Judgment on Mootness

Campbell-Ewald Company v. Gomez, No. 14-857

Article III of the Constitution limits the jurisdiction of federal courts to "cases" and "controversies." As the Supreme Court recently explained in Genesis HealthCare Corp. v. Symczyk, 133 S. Ct. 1523 (2013), a lawsuit does not present an Article III case or controversy and "must be dismissed as moot" when "an intervening circumstance deprives the plaintiff of a 'personal stake in the outcome of the lawsuit,' at any point during the litigation." Today, in Campbell-Ewald Co. v. Gomez, No. 14-857, the Supreme Court held that a defendant's unaccepted

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