DOL Won’t Request Liquidated Damages Under the FLSA Before Filing a Lawsuit

July 14, 2025

 

What's New

The Department of Labor (DOL) Wage and Hour Division has returned to its policy of not seeking liquidated damages in pre-litigation settlements of Fair Labor Standards Act (FLSA) claims.  Recent Democratic administrations sought liquidated damages, in addition to back pay, at the settlement stage to increase financial recoveries for workers. However, DOL now argues that the FLSA authorizes liquidated damages only during litigation.

What It Means

Liquidated damages under the FLSA can be a big deal for employers. Damages may equal and are in addition to the sum of unpaid minimum wages or overtime compensation for non-exempt employees – millions of dollars in some cases – for violations such as worker misclassification or off-the-clock work. In other words, the employer can be liable for a larger penalty, effectively doubling the amount due.

DOL’s current policy should make it easier for employers to settle alleged violations with DOL. However, it is possible plaintiffs’ attorneys will advise clients to seek redress in court rather than through DOL.

What You Should Do

Employers currently under a DOL investigation into potential FLSA violations should consult counsel about whether the new environment makes settlement a more attractive option. Employers seeking to enhance in-house expertise with the FLSA should consider CWC’s online and customized training for employers on FLSA principles, such as our Fundamentals of Wage and Hour Compliance course.





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