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2016 All Over Again: Texas Judge Rejects FLSA Exemption Salary Hike, Restores $35,568 Minimum

A federal district judge has vacated the U.S. DOL’s 2024 rulemaking increasing the minimum salary employers must pay to exempt executive, administrative, and professional employees. That minimum now reverts to an annualized...more

Fifth Circuit Ruling: 2019 Salary Threshold Increase Did Not Exceed Authority

Seyfarth Synopsis: On September 11, 2024, a panel of the U.S. Court of Appeals for the Fifth Circuit held in Mayfield v. U.S. Department of Labor that the Secretary’s salary test for evaluating overtime exemptions are valid...more

Injunction Party of One: New OT Rule Takes Effect for All Employers…Except the State of Texas

The DOL’s revised overtime exemption rule took effect yesterday, July 1, 2024. While several lawsuits are challenging the rule, a last-minute injunction was ultimately granted for only one employer: the State of Texas. The...more

Ripples in the OT Waters: Considering the Downstream Effects of Reclassifying Exempt Employees

Seyfarth Synopsis: With the DOL’s new overtime exemption rule weeks from taking effect, employers must consider the impacts of reclassifying exempt employees. Some potential impacts are obvious, others not so much. Proactive,...more

U.S. DOL Releases Final Overtime Rule—Effective July 2024

Yesterday, the U.S. DOL unveiled its final overtime rule. The rule significantly increases the minimum salary for so-called “white collar” employees to be exempt from the federal FLSA’s overtime pay requirements. This...more

DOL Delivers a Proposed Salary Bump to FLSA Overtime Thresholds for Labor Day

Just days before Labor Day, the U.S. Department of Labor (“DOL”) unveiled its Notice of Proposed Rulemaking (“NPRM”), aimed at revising the Fair Labor Standards Act’s overtime exemptions for executive, administrative, and...more

Meet the New Interpretation, (Pretty Much the) Same as the Old Interpretation: the DOL Proposes Its Own Independent Contractor...

Seyfarth Synopsis: Today the U.S. Department of Labor issued its draft new interpretive regulation (or NPRM) attempting to define employee versus independent contractor status under the Fair Labor Standards Act. The NPRM...more

On Deck for ’22: Exempt Salary Level Increases and Prevailing Wage Changes

Seyfarth Synopsis: On December 10, 2021, the White House and U.S. Department of Labor confirmed their plan to propose new rules to increase the salary threshold for exempt employees under the FLSA and “modernize” the...more

No Substitutions: DOL Finalizes Time-Based Limit on Non-Tipped Work By Tip Credit Employees

Seyfarth Synopsis: Last week, the U.S. DOL issued a final rule limiting use of the FLSA’s tip credit for tipped employees who sometimes perform non-tipped work. Declining a more flexible approach advocated by many employers...more

Preparing for WHD’s Less-Carrot-More-Stick Enforcement Approach

Gone are the days when the U.S. DOL’s Wage & Hour Division (“WHD”) invited employers to proactively identify and collaborate with the Division to fix their wage and hour missteps. Closed is the chapter in which employers...more

New Year’s Gift From WHD: Guidance on Continuous Workday Rule in the WFH Era

Seyfarth Synopsis. In the final hours of 2020, the U.S. DOL’s Wage & Hour Division issued an opinion letter containing guidance on the compensability of time commuting to the office, or tending to personal matters, for...more

Fluctuating Workweek + Incentive Pay = No Problem—DOL Sends Final Rule to White House

Seyfarth Synopsis: The U.S. Department of Labor’s Wage & Hour Division has entered the final phase of issuing a new rule concerning the fluctuating workweek (FWW) method of compensation under the FLSA. ...more

WFH is the New Black, Part 2: The DOL Presses Pause on the “Continuous Workday” Rule

Seyfarth Synopsis: The U.S. DOL has suspended its “continuous workday” rule for employees working from home as a result of COVID-19. This development has major implications for how small businesses may schedule and...more

Does a Third-Party’s Bonus Payment to Your Employees Require You to Pay More Overtime? Citing Clark Griswold, Appeals Court Says...

Seyfarth Synopsis: On Tuesday, the Third Circuit issued a decision rejecting the U.S. DOL’s general position that incentive bonuses paid to employees by a third-party must be factored into overtime pay. While the decision...more

Regulatory Spring: Rulemaking by the Wage & Hour Division

Earlier last week, the comment period ended for the U.S. Department of Labor, Wage & Hour Division’s proposed rule increasing the salary threshold for the FLSA’s white collar exemption. The proposal received more than...more

Regulatory Spring: Rulemaking by the Wage & Hour Division

Welcome to our latest installment of Regulatory Spring, Seyfarth Shaw’s weekly blog series covering the U.S. Department of Labor’s three-headed effort to revise and modernize various core components of the Fair Labor...more

April Rules: DOL Continues Rulemaking Sprint With New Proposed Joint Employment Standard

Seyfarth Synopsis: On April 1, 2019, the U.S. DOL announced a proposed rule to clarify joint employment under the FLSA. The rule would establish a four-factor balancing test for joint employer status....more

Obama Overtime Rule Invalidated by Federal Court in Texas

Seyfarth Synopsis: On Thursday afternoon, a federal judge in Texas issued an order officially invalidating the U.S. Department of Labor’s 2016 overtime rule, which would have more than doubled the minimum salary level for...more

Finally Briefed: DOL Files 5th Circuit Reply Defending its Authority to Set Salary Level for EAP Exemptions

At last, the federal government has filed its reply brief in the Fifth Circuit concerning its appeal from a Texas district court’s order preliminarily enjoining the 2016 revisions to the FLSA’s executive, administrative, and...more

Acosta Takes the Helm

Seyfarth Synopsis: Last Thursday, the Senate confirmed Alexander Acosta as the 27th United States Secretary of Labor. Filling the final post in President Trump’s cabinet, Acosta will lead a Department of Labor that has,...more

New Rules, New Secretary? As Spring Inches Closer, We’re Getting Warmer.

Will the Department of Labor’s new overtime rule go into effect? When will a new Secretary of Labor be confirmed? We don’t have the answers just yet, but a lot has happened over the last few weeks to inch us closer. As things...more

Seyfarth Submits Comments in Response to Proposed Overtime Rules

On Friday, Seyfarth’s Wage & Hour Litigation Practice Group submitted its comments to the Wage and Hour Division’s recent Notice of Proposed Rulemaking. As our readers know, the NPRM signals a potential overhaul to the FLSA’s...more

How Retailers Can Navigate the New White-Collar Overtime Rules: Turning Legal Change Into Business Opportunity

The Department of Labor’s proposed revisions to the Fair Labor Standards Act’s overtime exemptions will impact the American workplace—and especially the retail workplace—as much as any legal development in the past decade. ...more

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