[Michlib-l] New DoL Overtime Rule and new Salary Basis Overturned by U.S. Federal District Court in Texas.

[Membiela, Clare (MDE)]

Hello!


Fifth Circuit Court of Appeals overturns Department of Labor Overtime Rule and the increased salary level for "exempt" qualification.

Texas v. U.S. Department of Labor, 24cv00499, U.S.Dist.E.D.Tx, 11/15/2024, halted the further implementation or enforcement of the rule, including the increases implemented in July 2024.

Although the decision is a Texas Federal Court, the decision affects the implementation/enforcement of the rule in all 50 states.

The DoJ may appeal, but current thinking is that they are unlikely to, given the new administration taking office in January.

This opinion's analysis used the recent Supreme Court decision which overturned the longstanding Chevron Doctrine, and changing how courts may interpret federal agency actions and interpretations.

The Texas decision means that the Salary Basis test for purposes of determining Exempt or Non-Exempt status will revery back to $684 per week ($35,568 per year).

If your library has already made changes to policy and/or salary structure in preparation for the new rule, please contact your attorney to determine how this change affects your plans.

As always, questions on overtime status and policy should be addressed with your library's lawyer.

If anyone is interested in a copy of the opinion, I have a copy I am willing to share. Just e-mail me!

Here are some links to informational articles on this opinion

National Law Journal - https://www.jdsupra.com/legalnews/it-s-deja-vu-all-over-again-federal-1468213/
ADP - https://www.adp.com/spark/articles/2024/11/federal-court-strikes-down-us-dol-overtime-exemptions-rule-nationwide.aspx

Thanks!
Clare

Clare D. Membiela, MLS, J.D.
Library Law Consultant
Library of Michigan
MembielaC at michigan.gov<mailto:MembielaC at michigan.gov>
517-335-8132

The research and resources above are for informational purposes only and not for the purpose of providing legal advice. You should contact your attorney to obtain advice with respect to any particular issue or problem.

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