The U.S. Supreme Court’s recent decision in Perez v. Mortgage Bankers Ass’n invalidated a significant line of  D.C. Circuit case law known, after the leading case, as the Paralyzed Veterans doctrine.  A case involving a series of contradictory Department of Labor interpretations of whether mortgage loan officers are exempt from minimum wage and overtime guarantees, Perez holds that the Paralyzed Veterans doctrine is incompatible with the plain language of the Administrative Procedure Act (APA) and impermissibly imposes notice-and-comment requirements on interpretive rules.… Continue Reading