In its September 11, 2024 opinion in Mayfield v. Department of Labor, the United States Court of Appeals for the Fifth Circuit held that the U.S. Department of Labor’s explicitly delegated authority to “define” and “delimit” the terms of the executive, administrative, and professional (EAP) exemptions includes the power to set a minimum salary for exemption.
In 2019, DOL issued a final rule raising the minimum salary required to qualify for most EAP exemptions from $455 per week to $684 per week. In 2024, DOL issued a final rule raising the minimum salary to $844 effective July 1, 2024 and to $1,128 effective January 1, 2025.
In Mayfield, the plaintiff, a small business owner, challenged the 2019 rule, arguing that DOL lacks, and has always lacked, the authority to define the EAP exemptions in terms of salary level (as opposed to by job duties). The district court granted DOL’s motion for summary judgment, and Mayfield appealed.
After noting that its own precedent did not answer the question before it and that the “major questions” doctrine did not apply, the Court turned its eyes to the Supreme Court’s July 2024 opinion in Loper Bright Enterprises v. Raimondo and noted that “where, as here, Congress has clearly delegated discretionary authority to an agency, we discharge our duty by ‘independently interpret[ing] the statute and effectuat[ing] the will of Congress subject to constitutional limits.’” Because of Congress’s “uncontroverted, explicit delegation of authority”...
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