The Department of Labor acted within its authority in requiring employers to pay a minimum salary to employees who are classified as exempt from federal minimum wage and overtime requirements, the U.S. Court of Appeals for the Fifth Circuit ruled September 11 in Mayfield v. DOL.
A unanimous three-judge panel noted that DOL has included a minimum-salary requirement in the white-collar exemption to the Fair Labor Standards Act for more than 80 years. The court observed that Congress has implied its acceptance of a minimum salary test by amending the FLSA many times without modifying or foreclosing the minimum salary rule.
Notably, Mayfield involves not the Biden Administration’s 2024 rule but the 2019 Trump Administration rule that set a much lower salary level. The Fifth Circuit did not address the reasonableness of the amount of the Trump rule’s salary level because it was not at issue in this case. However, the amount of the salary level is the primary focus of legal challenges to the Biden rule. The Mayfield ruling’s impact on that issue remains to be seen.
Members of the Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, can read more here.