Court Blocks DOL Rule Increasing Salary Threshold for White-Collar Overtime Exemption

November 21, 2024

 

What's New

A federal district court has vacated a Labor Department rule that increased the minimum salary level for the “white-collar” overtime exemption. Therefore, the prior minimum salary threshold of $684 weekly is back in effect. The opinion came November 15 by the U.S. District Court for the Eastern District of Texas in Texas v. U.S. Dep’t of Labor

The Biden Administration’s final rule increased the salary threshold for executive, administrative, and professional employees in two phases. On July 1, 2024, the minimum salary level increased to $844 per week. It was set to increase to $1,128 per week on January 1, 2025. The rule also would have increased the minimum salary threshold for “highly compensated employees.” These changes would have made many additional employees eligible for overtime pay.

The court concluded that the rule exceeds DOL’s authority under the Fair Labor Standards Act because it “effectively eliminates consideration of whether an employee performs bona fide executive, administrative, or professional” duties and instead uses a salary-only test.

Furthermore, the court concluded that salary-level updates must be made through the notice-and-comment process rather than through automatic increases.

What It Means

With the rule vacated, employers can pause their plans to comply with the expected January 1, 2025, increase—such as salary increases to meet the minimum, reclassification of employees as nonexempt, or workforce restructuring.

What You Should Do

Employers may wish to consider whether it is appropriate to rescind any adjustments that they made to comply with the July 1, 2024, increase.





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