Picture this: You’re in a management position at your company, pulling 50-60 hour workweeks, but still getting the same paycheck week after week. Your boss tells you it’s because you’re an “exempt” employee under the Fair Labor Standards Act (FLSA). No overtime pay, just a set salary. The catch? Your salary doesn’t even hit the federal minimum for “exempt” employees. If that sounds familiar, you’ve got a case against your employer—and they could be violating federal law.
The Mayfield Case and the DOL’s Power
A key case, Mayfield and R.U.M. Enterprises, Inc. v. U.S. Department of Labor, put the DOL’s authority under the spotlight. A fast-food franchise owner claimed that the DOL overstepped by enforcing a minimum salary requirement for exempt employees. The employer argued that Congress never intended salary to factor into exemptions for executive, administrative, and professional (EAP) employees under the FLSA. They contended that job duties should be the sole consideration.
The courts didn’t agree. Citing a 2019 DOL rule, the Fifth Circuit affirmed that setting a minimum salary as part of the EAP exemption is well within the DOL’s statutory authority. The court made it clear: while the FLSA doesn’t mention salary requirements, it does delegate authority to the DOL to define the exemptions, and that includes imposing salary thresholds. As long as the salary requirement has a rational connection to determining who qualifies as an EAP employee, the DOL is in the clear.
What This Means for the 2024 Rule Changes
Now, fast forward to 2024. The DOL is rolling out new salary thresholds for white-collar exemptions, and employers aren’t happy. The minimum salary to qualify for an exemption increased to $844 per week on July 1, 2024, with a second jump to $1,128 scheduled for January 1, 2025. That’s a big hike from the previous level of $684 per week.
Employers have filed lawsuits, claiming that these changes push the boundaries of the DOL’s authority. However, the Mayfield ruling, while focused on the 2019 rule, leaves the door open for challenges to these higher thresholds. The question is whether the DOL can set the bar so high that it makes salary the overriding factor, effectively overriding the duties test. In other words, could a steep salary increase mean someone no longer qualifies as exempt, even if they meet all the duties of an executive or professional? Courts are still wrestling with that issue.
One Texas judge has already shown skepticism about the 2024 rule. In State of Texas v. U.S. Department of Labor, Judge Sean Jordan temporarily blocked the salary hike, suggesting that the new thresholds might go too far. But this isn’t the final word, and all signs point to more legal showdowns before the January 2025 increase.
Why This Matters to Employers—and Employees
At the heart of these legal battles is the fundamental question: Who gets paid overtime and who doesn’t? For employees, this is huge. If you’re putting in long hours and your salary doesn’t meet the minimum set by the DOL, your employer could be in violation of the FLSA. Even if your job title makes you “management,” if your paycheck doesn’t hit the right threshold, you might be owed back wages for all that overtime.
If you think your employer is skirting the law by classifying you as “exempt” while paying you less than the required minimum salary, you’re not alone. The rules are clear: If you don’t meet the salary minimum, you’re entitled to overtime pay. At Feldman Legal Group, we fight for workers who’ve been wronged. Reach out today to learn how we can help you get what you’re owed.
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