The following are summaries of selected civil opinions issued by the Fifth Circuit in September 2024. The summaries are overviews of particular aspects of the opinions; please review the entire opinions.
ADMINISTRATIVE LAW: Department of Labor’s minimum salary requirement did not exceed its delegated power to interpret the Fair Labor Standards Act’s “White Collar Exemption.”
Mayfield v. United States Department of Labor, 2024 WL 4142760 (5th Cir. Sept. 11, 2024).
In Loper-Bright, the Supreme Court jettisoned Chevron deference. But Loper-Bright did not disturb Congress’s power to delegate discretionary authority to agencies, including authority to interpret statutory provisions. A challenge to an agency’s exercise of that interpretive authority is judged by referencing the terms of the delegation, not by how a court would have interpreted the provision.
In this case, Mayfield, a small business owner, challenged a Department of Labor (DOL) rule that increased the minimum salary threshold for the “White Collar Exemption” from FLSA overtime and minimum wage requirements. The exemption applies to employees working in a bona fide executive, administrative, or professional capacity.