Judge Sean D. Jordan of the U.S. District Court for the Eastern District of Texas says in the opinion that, while the DOL has the authority to define and delimit the terms of the overtime exemption, “that authority ‘is not unbounded.’” The judge found that the department exceeded its statutory authority because “the minimum salary level imposed by the 2024 rule ‘effectively eliminates’ consideration of whether an employee performs ‘bona fide executive, administrative, or professional capacity’ duties in favor of what amounts to a salary-only test.”  The judge also found that the DOL’s automatic updates to the minimum salary threshold every three years “violates the notice-and-comment rulemaking requirements of the [Administrative Procedure Act].”