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Auto Technicians’ Pay Structure May Have Been Convoluted, But It Was Still A Bona Fide Commission Plan, Seventh Circuit Concludes

Although the employer’s pay system for its auto repair technicians was complicated and at times redundant, it nevertheless constituted a bona fide commissions compensation method subject to exemption from the overtime pay...more

Labor Department Formally Withdraws Trump-Era Joint Employer Final Rule

In an action anticipated since it issued its Notice of Proposed Rulemaking in March, the U.S. Department of Labor (DOL) officially has withdrawn the Joint Employer Final Rule published during the previous administration. The...more

Labor Department Brings Back The ‘80/20’ Rule — Along With New Companion, The ‘30-Minute’ Rule

The Department of Labor (DOL) has issued a new Notice of Proposed Rulemaking (NPRM), again seeking to regulate the circumstances under which an employer may pay a tipped employee a direct wage below the minimum wage. The NPRM...more

U.S. Department Of Labor Withdraws FLSA Independent Contractor Final Rule

Unsurprisingly, on May 5, 2021, the U.S. Department of Labor (DOL) withdrew its Independent Contractor Final Rule, published in the last days of the previous administration. The Final Rule, which never took effect, would...more

Labor Department Further Delays FLSA Tip Regulations Final Rule Until The End Of 2021

On April 28, 2021, the U.S. Department of Labor (DOL) announced that it will further delay, until December 31, 2021, the effective date of portions of the previous administration’s Tip Regulations Final Rule under the Fair...more

FLSA’s Extended Limitations Period Requires Plausible Factual Pleadings, Second Circuit Holds

Because the plaintiff failed to allege any facts supporting his claim that his former employer acted willfully in failing to pay him overtime, he was not entitled to the FLSA’s extended, three-year statute of limitations....more

DOL Adopts Portions Of Tipped Regulations Final Rule, Proposes Further Delay Of Other Portions

While deciding to make effective some portions of the Tipped Regulations Final Rule published in the final weeks of the former administration, the U.S. Department of Labor (DOL) has proposed further delay and consideration of...more

Biden DOL Proposes Withdrawal Of Former Administration’s Joint Employer And Independent Contractor Final Rules

On March 11, 2021, the U.S. Department of Labor (DOL) issued Notices of Proposed Rulemaking (NPRMs) to withdraw the Joint Employer and Independent Contractor Final Rules published during the previous administration...more

Full Fifth Circuit To Hear FLSA “Day Rate” Case, Vacating Panel Opinion

In April 2020, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit held that paying an employee a set amount for each day he works (i.e. on a “day rate” basis) does not satisfy the “salary basis” component...more

As Expected, DOL Delays Independent Contractor Final Rule

On March 2, 2021, the U.S. Department of Labor (DOL) formally delayed the effective date of the Independent Contractor Final Rule, from March 8, 2021 to May 7, 2021. The Final Rule, published during the last two weeks of the...more

DOL Delays Tip Regulations Final Rule, Independent Contractor Final Rule Likely Next

As expected, the U.S. Department of Labor (DOL) has formally delayed the effective date of the Tip Regulations Final Rule, from March 1, 2021 to April 30, 2021. The Tip Regulations Final Rule, issued in late December 2020,...more

The Proposed Federal Covid-19 Relief Bill Includes A $15 Minimum Wage Hike And Elimination Of The Tip Credit. Will Those...

Making good on President Biden’s campaign promise, the House of Representatives has included in its $1.9 trillion Covid-19 relief bill, known as the “American Rescue Plan Act of 2021,” revisions to the Fair Labor Standards...more

DOL Seeks To Delay Tip Regulations, Independent Contractor Final Rules

One day after President Biden entered office, the White House issued a memorandum directing all agencies to review, and consider delaying, any rules that had been issued by the former administration but that were not yet...more

Employers Will No Longer Get PAID

On January 29, 2020, the U.S. Department of Labor (DOL) announced that it was abandoning the Payroll Audit Independent Determination (PAID) program, effective immediately. PAID was introduced in 2018 as a self-audit program,...more

States Challenge DOL’s Tip Regulations Final Rule, DOL Withdraws Opinion Letters

On January 19, 2021, eight states (Delaware, Illinois, Maryland, Massachusetts, Michigan, New Jersey, New York, and Pennsylvania), along with the District of Columbia, filed a lawsuit seeking to enjoin the Tip Regulations...more

Trump DOL Rides Out On Wave Of Nine Opinion Letters

In 2017, then-Department of Labor (DOL) Secretary Alexander Acosta, appointed by former President Donald Trump, announced the Wage and Hour Division (WHD) would be reviving the practice of issuing Opinion Letters, seeking to...more

2020 Wage & Hour Developments: A Year In Review

In 2020, federal and state laws regulating wages and hours of work continued to change and develop, expanding in some areas, and contracting in others. In “2020 Wage & Hour Developments: A Year in Review,” we look back on...more

Department Of Labor Issues Final Independent Contractor Rule

The Department of Labor’s (DOL) Wage and Hour Division has formally released a Final Rule defining “independent contractors” under the Fair Labor Standards Act (FLSA). The regulation provides that “an individual is an...more

DOL Issues Opinion Letters Regarding Pay Calculations For Teleworkers, In-Home Caregivers

On the last day of 2020, the Wage and Hour Division of the U.S. Department of Labor (DOL) ushered out the year with two new Opinion Letters. These may be the final two Opinion Letters of the Trump Administration and perhaps...more

Labor Department Issues Final Rule On Tip Pooling Amendments, Elimination Of ‘20%’ Dual Jobs Rule

The U.S. Department of Labor (DOL) has issued its long-awaited Final Rule addressing who may share tips under the Fair Labor Standards Act (FLSA) and the circumstances under which employers may use a tip credit. The Final...more

U.S. Department Of Labor Proposes New Rule To Streamline Independent Contractor Analysis

The U.S. Department of Labor (DOL) has issued a new proposed regulation setting forth the proper standard for determining a worker’s status as an “independent contractor” under the Fair Labor Standards Act (FLSA)...more

Fifth Circuit Creates Circuit Split On FLSA’s “Regular Rate” Burden, Addresses Inclusion Of Bonuses

With specific, limited exceptions set forth in Section 207(e) of its regulations, the Fair Labor Standards Act (FLSA) requires that all compensation provided to a non-exempt employee must be included when determining the...more

DOL Issues New Opinion Letters On Fluctuating Workweek Hours Requirement, Other Topics

Continuing the practice it reinstituted during the current administration, on August 31, 2020 the U.S. Department of Labor’s (DOL) Wage Hour Division (WHD) issued four new Opinion Letters, addressing a variety of topics. That...more

DOL Issues Final Rule Permitting Use of Non-Salary Compensation Under “Fluctuating Workweek” Pay Method

On May 20, 2020, the U.S. Department of Labor (DOL) issued a Final Rule expressly permitting employers to provide additional pay, such as bonuses, commissions, or premiums, to employees when utilizing the “fluctuating...more

DOL Withdraws ‘Retail Or Service Establishment’ Lists For Commissioned Employee Exemption Analysis

The U.S. Department of Labor (DOL) withdrew its interpretative rules setting forth the types of businesses either not qualifying, or only possibly qualifying, as “retail or service establishments” when determining whether a...more

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