What’s next? The Potential Impact of the Fifth Circuit’s Mayfield Decision on the 2024 DOL Minimum Salary Rule
On September 11, 2024, the U.S. Court of Appeals for the Fifth Circuit joined four other federal courts and held that the U.S. Department of Labor (DOL) has statutory authority to impose a minimum salary threshold to qualify for the executive, administrative, and professional overtime exemptions (EAP Exemption) under the Fair Labor Standards Act (FLSA ). Mayfield and R.U.M. Enterprises, Inc. v. U.S. Dep’t of Labor , No. 23-507-24 (5th Cir. Sept. 11, 2024) . The Fifth Circuit’s decision was in response to a legal challenge related to the 2019 DOL Final Rule on overtime pay, which increased the minimum salary requirement for the EAP Exemption . While seen as a win for the DOL in its effort to enforce its more recent 2024 Final Rule, the ruling does not address the validity of the 2024 Final Rule, and leaves open other possible challenges to the 2024 Final Rule. Overview of the DOL Minimum Salary Rules In 2019, the DOL promulgated a new version of its “Minimum Salary Rule,” raising t...