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DC Circuit Finds DOL’s Unilateral Reversal of Prior Published Enforcement Position Exceeded its Authority; Public Notice and Comment was Required

On July 12, 2013 by Schnader in Labor and Employment

By Scott J. Wenner On the heels of a series of high-profile appellate defeats suffered by the NLRB’s efforts at rulemaking, the United States Court of Appeals for the District of Columbia Circuit found that the Department of Labor’s Wage & Hour Division (WHD), exceeded its authority in unilaterally publishing its […]

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DC Circuit Finds DOL’s Unilateral Reversal of Prior Published Enforcement Position Exceeded its Authority; Public Notice and Comment was Required

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