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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

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

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

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

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

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

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

Chicago Passes Expansive Fair Workweek Law

Seyfarth Synopsis: On Wednesday, the Chicago City Council passed the Chicago Fair Workweek Ordinance, arguably the most expansive law of its kind. When the law takes effect in July 2020, it will require covered employers to...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

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

Looking Ahead to Exhibit A: Tips For Drafting Job Descriptions for Exempt Employees

Seyfarth Synopsis: Each year, droves of employers are hauled into court to defend lawsuits in which salaried-exempt employees claim that, because of their job duties, they should have been classified as non-exempt and paid...more

Tired Of Waiting For FLSA Litigation? Meet PAID, WHD’s Pilot Program For Proactive Employers.

On Tuesday, the Wage & Hour Division announced a new program for resolving violations of the FLSA without the need for litigation. The Payroll Audit Independent Determination program—or “PAID”—is intended to facilitate the...more

The Road To FLSA Litigation Is Often Paved With Good Intentions

Even as FLSA litigation has surged to historic highs, it is rare to see a nefarious violation of the Act by a manager or supervisor. Far more prevalent, it seems, are stories of managers who, while intending to afford...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

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