Jeremy Glenn was quoted in a Law360 article examining recent developments in the ongoing debate over the tipped minimum wage. Policymakers in Chicago and Washington, D.C. have reached legislative compromises to delay prior plans to end tip credit, while Massachusetts voters rejected a ballot measure to end tipped minimum wage.

Regarding Chicago’s recent compromise to delay the phase-out of the tip credit, Jeremy stated, “This doesn't change where Chicago is headed, which is a progressive labor-wage city. It just gives employers more time to get there.” He characterized the outcome as “a classic Chicago compromise,” where both sides claimed partial victory despite concessions. Jeremy added that wage preemption laws are not expected to move forward in Illinois, saying “That's a greater concern in states where there's a distinction between the political party of the governor and local government.”

Jeremy also pointed to compliance challenges associated with evolving tipped wage laws, particularly as jurisdictions implement gradual changes. He stated that fluctuation in rates can increase litigation risk, explaining that “it's easier for an employer to be caught unaware” and requires vigilance to track annual legal updates.

More broadly, Jeremy noted, “The tip credit is a complex legal maze,” and that employers will need to carefully navigate requirements related to wage calculations, overtime, and tip pooling.

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