In Smith v. Greystone Alliance, plaintiff filed a putative class action alleging that defendant violated the FDCPA.  Defendant served plaintiff with an Offer of Judgment, and after that was not accepted, moved to dismiss the case for lack of subject matter jurisdiction as the case had become moot.  The district court granted defendant’s motion, and plaintiff appealed.  The appellate court reversed, finding that the offer did not offer plaintiff full relief.  The court concluded by stating: “an offer that the defendant or the judge believes sufficient, but which does not satisfy the plaintiff’s demand, does not justify dismissal.”

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