On January 20, 2016, the US Department of Labor (“DOL”) became the latest federal agency to advocate for an expansive concept of joint employment. The DOL’s Wage and Hour Administrator took the position that joint employment under the Fair Labor Standards Act “should be defined expansively” and “as broad as possible.” The new Administrator’s Interpretation, along with the National Labor Relations Board’s recent joint employer ruling in Browning-Ferris, suggests a coordinated, federal push to expand joint-employer liability under a host of labor and employment law statutes. Read the full alert for an in-depth analysis of the DOL’s guidance and our thoughts on this coordinated federal effort.

Read the full alert.