DOL Rule Invalidated Regarding Salary Thresholds For "White Collar Exemptions"

Earlier this year, the U.S. Department of Labor ("DOL") implemented a rule increasing the salary thresholds for the so-called "white collar exemptions" to the Fair Labor Standards Act. On November 15, 2024, a federal district court in Texas vacated the rule nationwide, finding that the DOL had exceeded its authority in promulgating these increases.

In its decision, the court reasoned that the new salary thresholds were so high that they effectively displaced the "duties" component of the exemption tests, which evaluate whether the employee is performing duties sufficient to exempt them from overtime. The court further held that the DOL was not authorized to implement automatic increases to the salary threshold.