Updated November 21, 2024
As you might recall, the Department of Labor (“DOL”) issued a rule, effective July 1, 2024, that increased the minimum salary requirement for executive, administrative, and professional (“EAP”) employees from $684 per week ($35,568 per year) to $844 per week ($43,888 per year). The rule was also set to increase the salary requirement again January 1, 2025; July 1, 2027; and automatically every three years thereafter.
On November 15, 2024, a federal judge in Texas decided that the rule was unlawful because it exceeded the agency’s authority. As a result, the court set aside the rule, which means that the salary threshold reverted to $684 per week ($35,568 per year). While the DOL could appeal the decision to try and get the rule reinstated, the upcoming Trump administration may choose not to do so. For employers who increased employees’ salaries earlier this year to comply with this rule, please check with your legal counsel before reversing the salary increases. There could be broader implications, including those under Oregon’s Equal Pay Act and employee morale and retention, to be considered as part of this decision.
For more information, please contact our attorneys, Amanda Walkup, Mario Conte, and Elizabeth Stubbs.
This summary provides general information and should not be construed as legal advice or a legal opinion on any specific facts or circumstances. If you have specific legal questions, you are urged to consult with your attorney concerning your own situation.