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Attorneys and human resources executives advise a wait-and-see approach to two U.S. District Court rulings that struck down new salary minimums for exempt employees. Both cases have been appealed.
It’s been a head-spinning few months for employers, as a mandate that would have dramatically boosted the overtime salary threshold for white-collar workers was overturned in November by a federal judge—less than two months before its final phase was to take effect.
Since that time, another federal court ruling and a subsequent appeal of it by the Trump administration have added another element of uncertainty to the situation.
In April 2024, the U.S. Department of Labor issued a new rule that increased the salary at which some employees become eligible for overtime pay. Under the Fair Labor Standards Act, an employer is generally required to pay an employee time-and-a-half for every hour they work over 40 hours a week. However, some executive, administrative and professional employees are exempt from that requirement.
The Department of Labor sought to increase the dollar amount at which these white-collar workers become exempt. Part one, which took effect July 1, increased the annual salary threshold from $35,568 to $43,888. The change made an additional 1 million U.S. workers eligible to receive time-and-a-half wages for each hour they put in beyond 40.
On Jan. 1, 2025, the threshold was to increase again to...
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