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 tests for evaluating overtime exemptions
are valid and do not exceed the Department of Labor's
authority under the Fair Labor Standards Act
(“FLSA”).
Robert Mayfield, a Texas-based fast-food purveyor, challenged
the U.S. DOL Wage and Hour Division's 2019 rule, promulgated
during the Trump Administration, regarding executive,
administrative, and professional (“EAP”) exemptions
from overtime under the FLSA. Mayfield argued the rule exceeded the
Secretary of Labor's authority because the FLSA only allows
DOL to address a worker's duties, not to set a salary
threshold as part of the exemption analysis.