Federal court strikes down DOL rule increasing salary minimums under FLSA

On November 15, 2024, a federal judge in the Eastern District of Texas issued an order vacating and setting aside the regulatory amendments the Department of Labor (DOL) issued earlier in the year to the minimum salary levels for exempt status under the executive, administrative, and professional (EAP) exemptions under the Fair Labor Standards Act (FLSA).

Background

As you may recall, in March 2024, the DOL announced a final rule that would increase the minimum salary for exempt status under the EAP exemptions. The increases were on a staggered schedule, with an initial increase to $43,888 per year that took effect on July 1, 2024, and a more significant second increase to $58,656 per year, which was to take effect on January 1, 2025.

The final rule also implemented changes to the FLSA’s highly compensated employee (HCE) exemption, with the HCE threshold moving to $132,964 per year on July 1 and then to $151,164 per year as of January 1, as well as added an automatic updating of these minimum thresholds every three years.

What happened?