Mayfield v. United States Department Of Labor
117 F.4th 611 (2024)
Issues
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Nature Of The Case
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Facts
The Fair Labor Standards Act (FLSA) sets out a variety of standards and protections governing labor conditions. It sets a minimum wage and requires overtime for work beyond forty hours per week. The FLSA contains a series of exemptions that exclude certain types of employees from that definition. Relevant here, the FLSA exempts 'any employee employed in a bona fide executive, administrative, or professional capacity.' § 213(a)(1). That exemption is known as the 'EAP Exemption' or the 'White Collar Exemption, and it gives the Secretary of the Department of Labor the power to 'define and delimit' the 'terms' of the exemption. The Exemption defines qualifying workers through duties and job types. D has repeatedly issued a minimum-salary rule that prevents workers from qualifying for the Exemption if their salary falls below a specified level. D has justified the use of a salary-level test by pointing to its effectiveness as a screen for an employee's actual duties. In 2019, D issued a new version of the 'Minimum Salary Rule,' raising the minimum salary required to qualify for the Exemption from $455 per week to $684 per week, an increase of 50.3%. D is currently considering a proposed rule that would raise the minimum salary to $1,059 per week, a roughly 55% increase from the 2019 Rule. P sued D, claiming that the 2019 Rule exceeds DOL's statutorily conferred authority. P is a small-business owner who runs thirteen fast-food restaurants. P's businesses succeed by offering high bonus payments to the best-performing store managers. He asserts that the Rule forces him to pay a higher salary to all managers regardless of performance, leaving him with insufficient funds to reward the best performers. P argues that D lacks, and has always lacked, the authority to define the Exemption in terms of salary level. P and D filed cross-motions for summary judgment. The district court granted D's motion and denied P. P appealed.
Rule Of Law
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Holding & Decision
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Legal Analysis
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