The Families First Coronavirus Response Act (FFCRA) was enacted as part of the CARES Act in March 2020, and Congress tasked the U.S. Department of Labor (DOL) in administering and enforcing it. The DOL issued final regulations interpreting the FFCRA on April 1, 2020 (“Final Rule”). Shortly after, the State of New York brought suit against the DOL claiming that several fundamental portions of the Final Rule exceeded the DOL’s statutory authority and unduly restrict paid leave.
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