Law360, “DOL Wage Rulemaking Could Face Injunctions Complication,” quotes Dove A.E. Burns, Esq., 4-10-2026

Kaufman Dolowich’s Dove A.E. Burns, Regional Managing Partner of the firm’s California offices and Managing Partner of its New Haven office, was recently quoted in a Law360 article analyzing the impact of the U.S. Supreme Court’s decision in Trump v. CASA Inc. on challenges to Department of Labor rules.

The decision narrows courts’ ability to issue nationwide injunctions, increasing the likelihood of inconsistent rulings across jurisdictions. As Burns explained, this shift could significantly affect how employers navigate compliance on a national scale:

“This could mean the DOL won’t face a universal undoing of regulations, but also that a rule challenge might have different outcomes in various jurisdictions, leading to complications for larger employers. It’s going to be more circuit-by-circuit fragmentation based on CASA,” she said. “You will have a cascading impact of internal parity issues.”

She further noted that the decision is likely to influence litigation strategy, particularly in how and where challenges are brought:

“Another path forward for rule challengers is to file simultaneous suits in different forums. That way, if a court follows CASA and grants only a narrow injunction, the challengers can try to get multiple injunctions. Instead of rushing to a friendly forum like the Ninth Circuit, you’re going to see these advocacy groups file simultaneous litigation in a variety of forums in order to come to get the same outcome in terms of broader reach. Rule challengers might also argue that a rule has a multistate impact, so the court can’t just look at the jurisdiction in which the case is brought. That’ll push the boundaries of how far CASA is applied.”