Overtime Rule Complaint
Overtime Rule Complaint
Overtime Rule Complaint
Plaintiffs,
v.
UNITED STATES DEPARTMENT OF
LABOR; THOMAS E. PEREZ, in his
Official Capacity as United States
Secretary of Labor, THE WAGE AND
HOUR DIVISION OF THE
DEPARTMENT OF LABOR; DR.
DAVID WEIL, in his Official Capacity
as Administrator of the Wage and Hour
Division; MARY ZIEGLER, in her
Official Capacity as Assistant
Administrator for Policy of the Wage
and Hour Division,
Defendants.
1
DOLs use of, and conclusive emphasis on, the salary test defies the statutory
text of 29 U.S.C. 213(a)(1), Congressional intent, and common sense. One would
thinkas the statute indicatesthat actually performing white collar duties (i.e.
being employed in a [white collar] capacity) would be the best indicator of white
collar exempt status. Instead, DOL relegates the type of work actually performed to
a secondary consideration while dangerously using the salary basis test,
unencumbered by limiting principles, as the exclusive test for determining overtime
eligibility for EAP employees.
Worse still, under the guise of interpretation, DOL included in their final rule
an automatic indexing mechanism to ratchet-up the salary level every three years
without regard for current economic conditions or the effect on public and private
resources. Indexing not only evades the statutory command to delimit the exception
from time to time, as well as the notice and comment requirements of the
Administrative Procedure Act (APA), it also ignores DOLs prior admissions that
nothing in the legislative or regulatory history would support indexing or
automatic increases . The Department believes that adopting such approaches in
this rulemaking is both contrary to congressional intent and inappropriate. 69
Fed. Reg. 22122, 2217172 (Apr. 23, 2004).
The new rule exceeds Constitutional authorization too. Under the new
overtime rule, States must pay overtime to State employees that are performing
executive, administrative, or professional functions if the State employees earn a
salary less than an amount determined by the Executive Branch of the Federal
3
Government. And there is apparently no ceiling over which DOL cannot set the
salary level. The threat to the States budgets and, consequently, the system of
federalism, is palpable. By committing an ever-increasing amount of State funds to
paying State employee salaries or overtime, the Federal Executive can unilaterally
deplete State resources, forcing the States to adopt or acquiesce to federal policies,
instead of implementing State policies and priorities. Without a limiting principle
(and DOL has recognized none) the Federal Executive could deliberately exhaust
State budgets simply through the enforcement of the overtime rule. But even aside
from that possibility, there is no question that the new rule, by forcing many State
and local governments to shift resources from other important priorities to
increased payroll for certain employees, will effectively impose the Federal
Executives policy wishes on State and local governments. The Constitution is
designed to prohibit the Federal Executives ability to dragoon and, ultimately,
reduce the States to mere vassals of federal prerogative. Therefore, the new
overtime rule must be set aside as violative of the Constitution, the authority given
by Congress in 29 U.S.C 213(a)(1), and the APA.
I. PARTIES
1.
is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
2.
an employer that pays a salary less than $913 per week to certain of its employees
4
it is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
4.
is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
5.
it is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
6.
is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
7.
is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
8.
is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
9.
it is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
5
10.
it is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
11.
an employer that pays a salary less than $913 per week to certain of its employees
working in a bona fide EAP capacity.
12.
it is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity
13.
because it is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity.
14.
an employer that pays a salary less than $913 per week to certain of its employees
working in a bona fide EAP capacity.
15.
it is an employer that pays a salary less than $913 per week to certain of its
employees working in a bona fide EAP capacity
16.
17.
is subject to the new overtime rule because it is an employer that pays a salary less
than $913 per week to certain of its employees working in a bona fide EAP capacity.
18.
subject to the new overtime rule because it is an employer that pays a salary less
than $913 per week to certain of its employees working in a bona fide EAP capacity.
19.
which is subject to the new overtime rule because it is an employer that pays a
salary less than $913 per week to certain of its employees working in a bona fide
EAP capacity.
20.
is subject to the new overtime rule because it is an employer that pays a salary less
than $913 per week to certain of its employees working in a bona fide EAP capacity.
21.
which is subject to the new overtime rule because it is an employer that pays a
salary less than $913 per week to certain of its employees working in a bona fide
EAP capacity.
22.
23.
Defendant Wage and Hour Division is the Division within DOL that is
responsible for formulating, issuing, and enforcing the new overtime rule. See
U.S.C. 204(a); 29 C.F.R. 541.1; 81 Fed. Reg. 32391, 32549.
25.
responsible for the rules and regulations formulated, issued, and enforced by the
WHD, including the new overtime rule. He is sued in his official capacity.
26.
Mary Ziegler is the Assistant Administrator for Policy of the WHD and
she is responsible for the rules and regulations formulated, issued, and enforced by
the WHD, including the new overtime rule. She was also the designated recipient of
comments for the new overtime rule. She is sued in her official capacity.
II. JURISDICTION AND VENUE
27.
1331 because this suit concerns authority under the Constitution of the United
States and the Fair Labor Standards Act. This Court also has jurisdiction to compel
an officer of the United States or any federal agency to perform his or her duty
pursuant to 28 U.S.C. 1361.
28.
1391(e) because the United States, several of its agencies, and several of its
officers in their official capacity are Defendants; a substantial part of the events or
8
omissions giving rise to Plaintiffs claims occurred in this District; and the Plaintiff
State of Texas is an employer of workers in this District.
29.
under the APA, 5 U.S.C. 706, and the Declaratory Judgment Act (DJA), 28
U.S.C. 22012202. The Court is authorized to award injunctive relief under 28
U.S.C. 1361.
III. FACTUAL BACKGROUND
A. Legislative History
30.
It generally requires,
amongst other things, that employees engaged in commerce receive not less than
the Federal minimum wage for all hours worked and also receive overtime (at oneand-half times the regular rate of pay) for all hours worked in excess of a forty-hour
workweek. 52 Stat. 1060 (June 25, 1938).
31.
Section 13(a)(1) set forth the white collar exemption which excludes from both
minimum wage and overtime any employee employed in a bona fide executive,
administrative, or professional capacity . 52 Stat. at 1067. The white collar
exemption is now codified at 29 U.S.C. 213(a)(1) (The provisions of section 206
(except subsection (d) in the case of paragraph (1) of this subsection) and section 207
of this title shall not apply with respect toany employee employed in a bona fide
executive, administrative, or professional capacity (as such terms are defined and
delimited from time to time by regulations of the Secretary ).).
9
32.
authority, DOL issued its first regulation concerning the white collar exemption
approximately four months later, in October 1938. 3 Fed. Reg. 2518 (Oct. 20, 1938).
The regulations are embodied in 29 C.F.R. 541 et seq.
34.
exemption did not contain a salary test for all three categories; professional
employees were only assessed by the work customarily and regularly performed. 3
Fed. Reg. 2518; see also 81 Fed. Reg. at 32395, 32400, 32423.
35.
DOL did not add a salary test for all three categories until two years
later. 5 Fed. Reg. 4077. The salary test has been steadily raised and modified ever
since. See, e.g., 14 Fed. Reg. 7705 (Dec. 24, 1949); 14 Fed. Reg. 7730 (Dec. 28, 1949);
19 Fed. Reg. 4405 (July 17, 1954); 23 Fed. Reg. 8962 (Nov. 18, 1958); 26 Fed. Reg.
8635 (Sept. 16, 1961); 28 Fed. Reg. 9505 (Aug. 30, 1963); 32 Fed. Reg. 7823 (May 30,
1967); 35 Fed. Reg. 883 (Jan 22, 1970); 38 Fed. Reg. 11390 (May 7, 1973); 40 Fed.
Reg. 7091 (Feb. 19, 1975).
36.
on a salary basis at a rate of not less than $455 per week . 29 C.F.R 541.600.
Similarly, so-called Highly Compensated Employees (HCEs) must have a total
10
annual compensation of at least $100,000 [to be] deemed exempt under section
13(a)(1) . 29 C.F.R. 541.601.
B. Supreme Court Precedent
37.
subdivisions. 52 Stat. at 1060 3(d) (Employer shall not include the United
States or any State or political subdivision of a State .).
38.
in the 1960s, 75 Stat. 65 (May 5, 1961); 80 Stat. 830, 831 (Sept. 23, 1966), and
attempted to extend coverage to all public sector employees in 1974. 88 Stat. 55, 58
59 (Apr. 8, 1974). The 1974 amendments imposed upon almost all public employers
the minimum wage and maximum hour requirements that were previously limited
to employees engaged in interstate commerce.
39.
426 U.S. 833 (1976), that the Tenth Amendment limited Congresss power under the
Commerce Clause to apply FLSAs minimum wage and overtime protections to the
States. The Court recognized that [o]ne undoubted attribute of state sovereignty is
the States power to determine the wages which shall be paid to those whom they
employ in order to carry out their governmental functions, what hours those
persons will work, and what compensation will be provided where these employees
may be called upon to work overtime. Id. at 845.
40.
the Court. Id. at 84951. It held that the Federal Government does not have the
authority to usurp the policy choices of the States as to how they structure the pay
of State employees or how States allocate their budgets. Id. at 84648. The Federal
Government cannot dictate the terms on which States hire employees. Id. at 849.
And it cannot force States to cut services and programs to pay for the Federal
Governments policy choices related to wages. Id. at 855. To permit the Federal
Government to manage State employment relationships would be to trample upon
the principles of federalism by regulating the States as States. Id. at 842, 845. If
Congress may withdraw from the States the authority to make those fundamental
employment decisions upon which their systems for performance of these functions
must rest, we think there would be little left of the States separate and
independent existence. Id. at 851 (quotations omitted).
41.
Almost a decade later, however, the Supreme Court backed away from
Over three decades of experience since Garcia has cast serious doubt
on the Courts optimistic reliance on mere politics to protect our federalist system
12
FLSAs white collar exemption and salary basis test to public employees in Auer v.
Robbins, 519 U.S. 452 (1997). The Court acknowledged that FLSA did not apply to
state and local employees when the salary-basis test was adopted in 1940. Id. at
457. Nonetheless, because the government Respondents in Auer concede[d] that the
FLSA may validly be applied to the public sector, and they also d[id] not raise any
general challenge to the Secretarys reliance on the salary-basis test, the Court did
not address those issues in Auer. Id.
C. The New Overtime Rule
44.
exemptions
from
the
[FLSA]s
overtime
requirement,
13
referred to as white collar exemptions) have not kept up with our modern
economy. Id.
46.
The President improperly equated the white collar exemption with the
federal minimum wage (which, in any event, only Congress can change): Because
these regulations are outdated, millions of Americans lack the protections of
overtime and even the right to the minimum wage. Id. (emphasis added).
47.
percentile of all full-time salaried employees [nationally] ($921 per week, or $47,892
for a full-year worker, in 2013) . Id. at 38517. The proposed nationwide standard
failed to account for regional and State variations in salaries and economic
vibrancy. Yet DOL nonetheless stated that such a level would accomplish the goal
of setting a salary threshold that adequately distinguishes between employees who
may meet the duties requirements of the EAP exemption and those who likely do not
. Id.
49.
DOL also proposed to set the HCE total compensation level at the
annualized value of the 90th percentile of weekly wages of all full-time salaried
employees ($122,148 per year) . Id.
50.
instance, regular updates to the duties componentthe best method to ensure that
these tests continue to provide an effective means of distinguishing between
overtime-eligible white collar employees and those who may be bona fide EAP
employees. Id.
52.
the workplace, 79 Fed. Reg. at 18737, DOL did not propose any revisions to the
standards duties test that has been in place since 2004. 81 Fed. Reg. at 32444.
Changes to the duties test were considered more difficult, so increasing the salary
level test was DOLs only answer to the problems and concerns that motivated the
Notice of Proposed Rulemaking. Id.
53.
The final rule was published on May 23, 2016. 81 Fed. Reg. 32391. It
set the new salary level based upon the 40th percentile of weekly earnings of fulltime salaried workers in the lowest-wage census region, which is currently the
South. Id. at 32404. Utilizing only data from the fourth quarter of 2015, DOL
determined that the required standard salary level will be $913 per week, or
$47,476 annually. Id. at 32405.
54.
The revised rule nearly doubles the previous salary test level of $455
per week.
15
55.
minimum overtime-exempt salary level for white collar employees. White collar
employees subject to the salary level test earning less than $913 per week will not
qualify for the EAP exemption, and therefore will be eligible for overtime,
irrespective of their job duties and responsibilities. Id. at 32405 (emphasis added).
DOL has concluded that white collar employees earning a salary of less than $913
per weeks are not bona fide EAP workers. Id. at 32419.
56.
DOL agreed with commenters, such as AFL-CIO, that the new salary
level test should be set relative to the minimum wage. 81 Fed. Reg. at 32405.
57.
do not have the same ability as private employers to increase prices or reduce
profits. Id. at 32421. In its opinion, basing the new salary level on the lowest wage
census region sufficiently addressed the concern of those governments. Id. Even so,
DOL perpetuated the special salary level historically applied to American Samoa.
Id. at 3242223.
58.
requirement for HCEs to the annualized weekly earnings of the 90th percentile of
full-time salaried workers nationally, which based on fourth quarter of 2015 data is
$134,004. Id. at 32429. Unlike the standard salary level test, DOL did not make a
regional adjustment to the HCE compensation level. Id.
59.
The revised salary level test and HCE compensation level will take
60.
Lastly,
the
new
rule
establishes
an indexing
mechanism
to
automatically update the standard salary level test and the HCE compensation
requirement every three years on the first of the year. Id. at 32430. The indexing
provisions are set forth in the new 541.607. Id. The first automatic ratcheting will
occur on January 1, 2020. Id.
61.
DOL admits that the Section 13(a)(1) exemption does not reference
automatic updating, a salary level, or the salary level test. Id. at 32431. While
simultaneously claiming authority to enact these regulations, DOL bluntly states
these regulations were all made without specific Congressional authorization. Id.
D. The Impact on State Governments and Businesses
62.
The Plaintiff States estimate that the new overtime rule will increase
their employment costs significantly based, in part, upon the number of salaried
EAP employees that will no longer be overtime exempt.
63.
Because
the
Plaintiff
States
cannot
reasonably
rely
upon
17
64.
the new overtime rule because the new rule displaces state policies regarding the
manner in which they will structure delivery of those governmental services which
their citizens require. See Natl League of Cities, 426 U.S. at 847.
65.
employees as hourly employees and reduce their hours to avoid the payment of
overtime. The Plaintiff States may also have to increase the workload of EAP
employees that will remain overtime exempt to accommodate the reduced workload
of reclassified workers. And the Plaintiff States may have to eliminate some
employment positions due to the new budgetary constraints.
66.
estimates that the new rule will add approximately $19.1 million of additional costs
on the State of Iowa government and its public universities in the first year.
67.
rule, the State of Arkansas estimates that approximately 3,995 employees reporting
through the Arkansas Administrative Statewide Information System (AASIS) will
no longer be overtime exempt. The resulting financial burden to the State in
additional annual employment costs and overtime/compensatory time accruals
would far exceed $1,000,000 if the State maintained its current level of overtime
usage and payouts.
68.
salaried EAP employees as hourly employees and limit those employees hours to
18
avoid the payment of overtime. Limiting and shifting workloads to avoid additional
overtime liability is likely to result in the reduction of services or delays in the
provision of those services.
69.
The adverse impacts of the overtime rule are most noticeable on the
state level, as the State of Arkansas employs roughly 14% of the States
workforce. However, the drastic expansion of the salary threshold also directly
impacts all other public and private FLSA-covered employers, including small
businesses, low-profit margin businesses, and rural communities. The County
Quorum Courts of Baxter, Pope, Benton, White, and Marion Counties have passed
resolutions citing the undue hardship (financial and otherwise) that the new
overtime rule will impose upon employers and employees in the State of Arkansas
and requesting that the Arkansas Attorney General take legal action to protect the
interests and well-being of all Arkansas citizens.
71.
19
72.
Plaintiff States. Under the new overtime rule, the State of Maine estimates that
approximately 450 employees could be no longer overtime exempt. The State of
Maines biennial budget does not include funding to offset the resulting financial
burden
to
the
State
in
additional
annual
employment
costs
and
EAP employees as hourly employees and limit those employees hours to avoid the
payment of overtime. This will likely result in the loss of flex schedules over
Maines two-week pay period and the elimination of telecommuting for affected
employees, as well as other strategies to manage hours to conform with the States
biennial budget.
December 1, 2016, it will have approximately 1,600 state employees who will move
into the category of employees covered by the new rule, i.e. into non-exempt status.
20
76.
The State of Arizona also has about 1,437 employees that are currently
classified as exempt that are earning an annual salary less than the new
threshold. If there were no other changes to FLSA designation, and the only thing
that changed was an increase to the employees base salary to ensure they are at
least equal to the new threshold, the budgetary impact would be nearly
$10,000,000.
77.
Private employers in the Plaintiff States will suffer the same ill-effects.
The harm to the Plaintiff States private employers will impact the Plaintiff States
tax revenuethe same source from which they will now have to pay the Federal
Executives increased overtime pay requirement.
IV. CLAIMS FOR RELIEF
COUNT ONE
Declaratory Judgment Under 28 U.S.C. 2201-2202 (DJA) and 5 U.S.C.
706 (APA) that the new Rules at Issue Are Unlawful by Violating the
Tenth Amendment
78.
79.
The DJA empowers the Court to declare the rights and other legal
relations of any interested party seeking such declaration, whether or not further
relief is or could be sought. 28 U.S.C. 2201. Similarly, the APA requires this
Court to hold unlawful and set aside any agency action that is contrary to
constitutional right, power, privilege, or immunity. 5 U.S.C. 706(2)(B).
80.
The Tenth Amendment states that [t]he powers not delegated to the
United States by the Constitution, nor prohibited by it to the states, are reserved to
21
Commerce Clause to apply FLSA to the States and the 29 C.F.R. Part 541 salary
basis test and compensation levels.
82.
As set forth herein, enforcing FLSA and the new overtime rule against
the States infringes upon state sovereignty and federalism by dictating the wages
that States must pay to those whom they employ in order to carry out their
governmental functions, what hours those persons will work, and what
compensation will be provided where these employees may be called upon to work
overtime.
83.
FLSA and the new overtime rule commandeer, coerce, and subvert the
States by mandating how they structure the pay of State employees and, thus, they
dictate how States allocate a substantial portion of their budgets. See Natl Fedn of
Indep. Bus. v. Sebelius, 132 S. Ct. 2566, 2605 (2012) (The threatened loss of over 10
percent of a States overall budget, in contrast, is economic dragooning that leaves
the States with no real option but to acquiesce in the Medicaid expansion.).
84.
The new overtime rule regulates the States as States and addresses
relationships, services, functions, and budgets). Compliance with the overtime rule
directly impairs the States ability to structure integral operations in areas of
traditional governmental functions and there is no federal interest that justifies
State submission. See Hodel v. Va. Surface Min. & Reclamation Assn, Inc., 452 U.S.
264, 288 & n.29 (1981).
86.
overruled.
87.
Because the new rules and regulations are not in accordance with the
law as articulated above, they are unlawful, should be declared invalid, and should
be set aside.
COUNT TWO
Declaratory Judgment Under 28 U.S.C. 2201-2202 (DJA) and 5 U.S.C.
706 (APA) that the new Rules at Issue Are Unlawful by Exceeding
Congressional Authorization Salary Basis Test, HCE Compensation
Level, and Indexing
88.
89.
The DJA empowers the Court to declare the rights and other legal
relations of any interested party seeking such declaration, whether or not further
relief is or could be sought. 28 U.S.C. 2201. Similarly, the APA requires this
Court to hold unlawful and set aside any agency action that is in excess of
statutory jurisdiction, authority, or limitations, or short of statutory right. 5 U.S.C.
706(2)(C).
23
90.
213(a)(1), or FLSA generally, for the new indexing mechanism related to the
salary basis test and HCE compensation level.
94.
DOL has acknowledged that its historical use of a salary level and
salary basis test, as well as its future attempted use of indexing, are without
specific Congressional authorization. 81 Fed. Reg. at 32431. Invalid action does not
become valid through the passage of time.
24
95.
beyond any reasonable reading of the relevant statutory text that the new salary
level, salary basis test, HCE compensation level, and indexing mechanism are in
excess of Congressional authorization and must be declared invalid and set aside.
COUNT THREE
Declaratory Judgment Under 28 U.S.C. 2201-2202 (DJA) and 5 U.S.C.
706 (APA) that the new Rules at Issue Are Being Imposed Without
Observance of Procedure Required by Law Indexing
96.
97.
The DJA empowers the Court to declare the rights and other legal
relations of any interested party seeking such declaration, whether or not further
relief is or could be sought. 28 U.S.C. 2201. Similarly, the APA requires this
Court to hold unlawful and set aside any agency action that is without observance
of procedure required by law. 5 U.S.C. 706(2)(D).
98.
With exceptions that are not applicable here, agency rules must go
The Defendants are agencies under the APA, 5 U.S.C. 551(1), and
the new rules and described herein are rules under the APA. 5 U.S.C. 551(4).
101.
and HCE compensation level every three years, the indexing mechanism that will
be set forth in new 29 C.F.R. 541.607 violates the statutory command to define
25
DOL concedes that indexing will dispense with the need for frequent
rulemaking in violation of the statutory language and APA. 81 Fed. Reg. 32400.
103.
herein.
105.
The APA requires this Court to hold unlawful and set aside any agency
are not otherwise in accordance with the law, and must be declared invalid and set
aside.
COUNT FIVE IN THE ALTERNATIVE
Declaratory Judgment Under 28 U.S.C. 2201-2202 (DJA) and 5 U.S.C.
706 (APA) that the new Rules at Issue Are Unlawful by Improperly
Delegating Congressional Legislative Power
107.
herein.
26
108.
The DJA empowers the Court to declare the rights and other legal
relations of any interested party seeking such declaration, whether or not further
relief is or could be sought. 28 U.S.C. 2201. Similarly, the APA requires this
Court to hold unlawful and set aside any agency action that is contrary to
constitutional right, power, privilege, or immunity. 5 U.S.C. 706(2)(B).
109.
granted in a Congress of the United States. The text does not permit the
delegation of those powers so the Supreme Court has repeatedly said that when
Congress confers decisionmaking authority upon agencies Congress must lay down
by legislative act an intelligible principle to which the person or body authorized to
[act] is directed to conform. Whitman v. Am. Trucking Assns, 531 U.S. 457, 472
(2001) (quotations omitted).
110.
which DOL was to establish the qualifications of the white collar exemption. On the
contrary, Congress impermissibly conferred unlimited legislative authority on DOL.
111.
112.
power to establish a Federal minimum salary level for white collar workers through
the new overtime rules.
113.
Because the new rules and regulations are not in accordance with the
law as articulated above, they are unlawful, should be declared invalid, and should
be set aside.
V. DEMAND FOR JUDGMENT
Plaintiffs respectfully request the following relief from the Court:
114
must be set aside actions taken without observance of procedure required by law
under the APA;
117.
120.
implementing, applying, or enforcing the new overtime rules and regulations; and
121.
29
LUTHER STRANGE
Attorney General
State of Alabama
BILL SCHUETTE
Attorney General
State of Michigan
MARK BRNOVICH
Attorney General
State of Arizona
PHIL BRYANT
Governor
State of Mississippi
LESLIE RUTLEDGE
Attorney General
State of Arkansas
DOUG PETERSON
Attorney General
State of Nebraska
SAM OLENS
Attorney General
State of Georgia
SUSANA MARTINEZ
Governor
State of New Mexico
GREG ZOELLER
Attorney General
State of Indiana
MIKE DEWINE
Attorney General
State of Ohio
TERRY E. BRANSTAD
Governor
State of Iowa
SCOTT PRUITT
Attorney General
State of Oklahoma
DEREK SCHMIDT
Attorney General
State of Kansas
ALAN WILSON
Attorney General
State of South Carolina
MATTHEW G. BEVIN
Governor
Commonwealth of Kentucky
SEAN REYES
Attorney General
State of Utah
JEFF LANDRY
Attorney General
State of Louisiana
BRAD SCHIMEL
Attorney General
State of Wisconsin
PAUL LEPAGE
Governor
State of Maine
30