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Wednesday, December 3, 2025

Federal Court Decision Strikes Down the Department of Labor’s Increase in Salary Thresholds for Exempt Employees - JD Supra

On November 15, 2024, the United States District Court for the Eastern District of Texas, in State of Texas v. Plano Chamber of Commerce, struck down, on a nationwide basis, a Department of Labor (DOL) ruling which took effect earlier this year that increased the salary threshold for so-called white collar exemptions for executive, administrative, and professional employees.

The ruling was scheduled to take effect in two phases – an increase in the salary level from $684 per week to $844 per week (or from $35,568 annually to $43,888 annually), which took effect on July 1, 2024, and a second phased increase in the salary level from $844 per week to $1,128 per week (or from $43,888 annually to $58,656 annually) scheduled to start on January 1, 2025.

The District Court struck both of these salary increases, as well as the automatic indexing component of the regulation, the effect of which would increase the threshold on a going forward basis every three years. The fundamental grounds for the decision were that the DOL, in issuing the 2024 and 2025 salary threshold increases, exceeded its authority by, for all practical purposes, eliminating consideration of the substantive duties test for determining whether the exemption should apply for executive, administrative and professional employees.

With regard to the provision automatically increasing the minimum salary thresholds every three years, the District Court held that the DOL not only exceeded its authority but also...



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