Texas Federal Court Vacates Department of Labor’s New Overtime Rule

November 20, 2024

On November 15, 2024 a federal judge in Texas vacated the Department of Labor’s (DOL) overtime rule from April 2024. This Rule promulgated by the DOL sought to raise the Fair Labor Standards Act’s (FLSA) minimum salary thresholds for white-collar overtime exemptions.


U.S. hourly workers, unless subject to narrow exemptions, are entitled to overtime pay (over 40 hours/week) under the federal law. Many workers who are salaried are exempt from that requirement unless their salary is below a certain amount.


The Plaintiffs in the current matter argued that the DOL’s 2024 increase would have rendered the Executive, Administrative and Professional (“EAP”) exemption moot, as the salary-level increase under the 2024 increase would have already been above that of the salary-based inquiry as an alternative to the EAP exemption. Effectively, the Court stated that because the salary level minimum exemption was raised higher, making more employees overtime-eligible, the DOL was eliminating consideration of the EAP exemption, exceeding the DOL’s authority granted under law.  


On July 1, 2024, the minimum salary level was raised, per the rule, to the equivalent of $43,888 per year. The minimum salary level was also set to increase on January 1, 2025 to $58,656 per year.


This ruling invalidated the July 1, 2024 salary increase as well as the salary adjustments that had been included in the April 2024 rule by the DOL nationwide. The salary exempt status will go back to $35,568 per year, a result of the 2019 DOL rule. This ruling will most likely be appealed, stay tuned for further updates.


If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.

July 25, 2025
On June 27, 2025, the U.S. Supreme Court ruled in Trump v. CASA that federal district courts cannot block executive orders for the entire country. The Court held that such broad injunctions exceed the authority Congress granted under the Judiciary Act of 1789. Courts may now only stop enforcement for the parties in the case—not for everyone else. What Happened in the Case President Trump issued Executive Order 14160 in early 2025. It denies birthright citizenship to children born in the U.S. if neither parent is a citizen or lawful permanent resident. Multiple lawsuits followed. Three federal courts blocked the order nationwide. The Supreme Court disagreed. It sent the case back and told the lower courts to revise the injunctions to cover only the named plaintiffs. The Court did not decide whether the order itself violates the Constitution. It ruled only on how far a court’s injunction can reach. Why It Matters to Employers The ruling affects how quickly and widely federal courts can stop controversial policies, especially during fast-changing political cycles. Employers have often relied on national injunctions to pause new mandates on wages, workplace safety, pay transparency, and non-compete agreements. This decision limits that option. The Court said nothing about injunctions under the Administrative Procedure Act, which governs agency rules. But the opinion raises doubts about whether even those can continue on a nationwide scale. Justice Kavanaugh suggested they might, but the Court left that question for another day. What This Means for You No nationwide protection unless you sue If your business is not part of the case, you likely cannot rely on someone else’s win. You must litigate directly to get relief. Rules may take effect in one state and not another A federal court in Texas may block a rule, while a court in New York upholds it. National companies may face conflicting rules and inconsistent enforcement. Trade groups cannot shield you Even if your industry association wins an injunction, it may apply only to their members or to the parties named in the lawsuit. Older rulings may now shrink Past national injunctions—on vaccine mandates, non-compete bans, overtime rules, or joint-employer standards—could be challenged or narrowed based on this ruling. More class actions are likely Some plaintiffs may now push for class certification to restore broader relief. Employers could face more complex litigation as a result. Next Steps for Employers Identify any current or past rules your business has relied on that are being blocked nationwide. Confirm whether you were covered by name or just assumed you were protected. Reassess your risk exposure for pending federal actions under OSHA, the EEOC, the DOL, or the NLRB. Monitor APA-based injunctions to see whether courts continue to grant broad relief under that statute. Consider joining strategic litigation early if new executive orders or agency rules would harm your operations. You cannot assume another company’s lawsuit will protect you. The Court narrowed that path. To block a federal mandate, you may now need to act alone—or join the fight directly. Michael P. Lewis is an attorney at The Royal Law Firm with experience advising clients through the litigation process. Michael helps employers resolve workplace challenges with focus, precision, and judgment. He counsels and defends businesses across Massachusetts and Connecticut, handling matters involving discrimination, harassment, retaliation, wage and hour claims, restrictive covenants, and breach of contract. His practice includes litigation in state and federal courts and before administrative agencies. If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.