--- url: 'https://www.fmjlaw.com/federal-court-vacates-new-overtime-regulations/' title: Federal Court Vacates New Overtime Regulations author: name: Adam url: 'https://www.fmjlaw.com/author/adam-brownfmjlaw-com/' date: '2024-11-18T19:35:41+00:00' modified: '2025-09-30T18:33:16+00:00' type: post summary: Learn what this decision about the DOL's new overtime rules will mean for employers and HR Professionals. categories: - Article - Thought Leadership tags: - Employment - FLSA - HR - 'HR & Employment' - overtime published: true --- # Federal Court Vacates New Overtime Regulations On November 15, 2024, a Federal Judge in the Eastern District of Texas issued an order vacating the April 2024 final rule (“Final Rule”) promulgated by the U.S. Department of Labor (“DOL”), which addressed the minimum salary requirements for employees to be considered exempt from overtime under the executive, administrative, or professional exemption categories (known as the “white collar” or “EAP” exemption categories) *or *as an exempt highly compensated employee (the “HCE” exemption category) under the Fair Labor Standards Act (“FLSA”). *Commerce v. United States Department of Labor*, No. 4:24-CV-499-SDJ. (E. D. Tex. Nov. 15, 2024). ## Background on the Final Rule and Implementation The Final Rule included three parts: (1) the minimum salary was raised from $684 per week to $844 per week as of July 1, 2024; (2) the minimum salary would have been raised again to $1,128 per week as of January 1, 2025; and (3) a mechanism to raise the minimum salary requirements automatically every three years based on earnings data. The Eastern District of Texas Court vacated all three parts of the Final Rule. Most employers have already taken steps to comply with the July 1, 2024, salary increase, which was estimated to affect about one million employees. The minimum salary now reverts to the $684 per week requirement, but most employers will likely not choose to reverse pay raises already implemented. Planning for additional pay raises to comply with the January 1, 2025, deadline is no longer required, and employers can disregard that deadline. The second salary increase was expected to impact about three million employees. ## Decision to Vacate the Final Rule The Court’s ruling in the *Commerce *case is based on the concept that federal agencies cannot exceed the authority delegated to them by Congress. The U.S. Supreme Court recently ruled in *Loper Bright Enters. v. Raimundo* that Courts should not defer to federal agency interpretation of statutory law but should exercise their own independent interpretation. In *Commerce*, the Court based its decision on the text of the FLSA which refers to “duties,” not salaries, quoting another court’s opinion that “Congress elected to exempt employees based on the capacity of in which they are employed. It’s their duties not their dollars that really matter.” The DOL has the opportunity to appeal this Federal Court’s ruling, and the decision of whether to do so may also be affected by the upcoming change in federal administration. ## Takeaways This Federal Court decision about the Final Rule means that employers and their Human Resources professionals can disregard the January 1, 2025 deadline, and they will not be required to re-classify or increase salaries for exempt employees earning less than $1,128 per week. As noted, while many employers have already taken steps to comply with the July 1, 2024 salary increase, they may want to review changes they have already made. FMJ’s HR & Employment Law Practice Group is available to help audit your organization’s wage and hour practices, review and analyze compensation structures, and draft policies, create and implement strategies for the future, and train your staff on new policies related to wage and hour practices and employee classifications. If you are interested in connecting with an attorney to discuss questions or concerns about any of these new changes, or any other HR and Employment law matters, please reach out to [V. John Ella](https://www.fmjlaw.com/professional/v-john-ella/) or anyone else in our [HR & Employment Law Practice Group](https://www.fmjlaw.com/practice-area/hr-employment/). 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