Justice Kagan’s dissent in Genesis criticized the majority’s assumption that the individual claims were moot, maintaining that an unaccepted offer of judgment is a “legal nullity” with “no operative effect.” Id. at 1533 (Kagan, J., dissenting). Justice Kagan further contended that an offer that addresses only the named plaintiff’s individual claim is insufficient to moot either a FLSA collective action or a class action under Rule 23.
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On March 15, 2020, Ohio Secretary of State Frank LaRose (R) directed county boards of elections to offer curbside voting to "any voter that is concerned about coming inside a polling location." The secretary of state also directed election officials to accept absentee ballot applications until 3:00 p.m. on March 17, 2020, for voters ...