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ARTICLE · 17 SEPTEMBER 2024

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 tests for evaluating overtime exemptions...

United StatesEmployment and HR

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.

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