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PAID Back: DOL Revives Voluntary Self-Audit Program

The U.S. Department of Labor has officially revived its Payroll Audit Independent Determination (PAID) program. Designed to help employers proactively resolve FLSA issues—and now, for the first time, certain FMLA...more

1 Big Bill + 2 New Deductions = Multiple New Challenges

The freshly enacted “One Big Beautiful Bill” introduces two above-the-line tax deductions for tips and overtime wages. While these deductions offer potential savings for eligible workers, they come with new compliance...more

WHD Makes it Clear: Double Damages are (Liqui)Dated

The DOL’s Wage and Hour Division just scrapped its policy of seeking liquidated damages (double damages) in FLSA investigations. Why? Because it probably didn’t have the statutory authority in the first place, and doing so...more

“Dear DOL”: Labor Department Re-Launches Opinion Letter Program

In a welcome development for employers navigating complex federal employment laws, the U.S. Department of Labor has announced the re-launch of its opinion letter program across several agencies, including the Wage and Hour...more

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

A “Strong Likelihood” of Change: Sixth Circuit Joins the Fifth in Raising the FLSA Certification Bar

Seyfarth Synopsis. Businesses familiar with FLSA litigation are aware of the frustrating ease with which some courts have turned single-plaintiff cases into large-scale collective action proceedings. But the tides are...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

2021 Trade Secrets Webinar Series: Takeaways & Recordings

Throughout 2021, our dedicated Trade Secrets, Computer Fraud & Non-Competes Practice Group hosted a series of CLE webinars that addressed significant trade secret and restrictive covenant issues facing clients today. This...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

Eleventh Circuit Clears the Road to Arbitration for Last-Mile Drivers

Seyfarth Synopsis: Though it may sound esoteric, the question of whether “last mile” drivers fall within the Federal Arbitration Act’s transportation worker exemption bears tremendous consequence. If they are exempt, they...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

Passport Rejected — A New Twist in the COVID-19 Passport Chapter

Seyfarth Synopsis: Similar to mask mandates, COVID-19 passports—a means to prove one’s vaccination status—are becoming a political lightning rod in the United States. Where states like New York have viewed such passports as a...more

Legal Update: The Road to “Normal” is Filled With…COVID Passports?

Seyfarth Synopsis: “I can’t wait for things to return to normal.” We’ve all heard (and most of us have spoken) those words since the COVID-19 pandemic began over a year ago. Now, as the employer community inches closer to the...more

The Road to “Normal” is Filled With…COVID Passports?

“I can’t wait for things to return to normal.” We’ve all heard (and most of us have spoken) those words since the COVID-19 pandemic began over a year ago. Now, as the employer community inches closer to the time we longed...more

The Fight For $15 Returns to Congress

Seyfarth Synopsis. Democrats in the U.S. House and Senate have reintroduced a bill to increase the federal minimum wage to $15 for virtually all non-exempt workers. While the “Fight For Fifteen” has made several trips to...more

De-Muddying the Waters: WHD Addresses Exempt Status of Account Managers

Seyfarth Synopsis: On January 8, the U.S. DOL’s Wage & Hour Division issued an opinion letter confirming the exempt status of Account Managers at a life sciences manufacturing company under the FLSA’s administrative...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

COVID-19 Liability Shields: Today’s Legislative Trend, Tomorrow’s Legal Defense

Seyfarth Synopsis: State lawmakers continue to search for ways to pave the path for their economies to reopen amidst the COVID-19 pandemic. The latest trend in that effort: equipping businesses with a shield against legal...more

Not a Typo: Georgia Enacts a Stringent Employment Law

Seyfarth Synopsis: Some states are known for setting high legislative bars with respect to employment rights and protections (looking at you, California). The State of Georgia isn’t one of them. Earlier this month, however,...more

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