Comment Letter to the Department of Labor’s Proposed Rule for Independent Contractor Status

Dear Director Navarrete:

The Manhattan Institute for Policy Research is a 501(c)(3) nonprofit think tank committed to developing and disseminating new ideas that foster greater economic choice and individual responsibility. Legal Policy Fellow C. Jarrett Dieterle of the Manhattan Institute submits these comments in response to the Wage and Hour Division’s notice of proposed rulemaking on Employee or Independent Contractor Status Under the Fair Labor Standards Act, Family and Medical Leave Act, and Migrant and Seasonal Agricultural Worker Protection Act.

My name is Jarrett Dieterle, and I am a legal policy fellow with the Manhattan Institute. In this role, I develop and communicate novel, sound ideas on how to improve America’s constitutional, legal, and regulatory systems of governance. I have testified before Congress and submitted regulatory comments to federal agencies, as well as provided testimony and input to numerous state legislatures. I have authored many policy briefs, articles in journals including National Affairs and the Georgetown Law Journal, and short-form commentaries in popular publications such as the New York Times, Wall Street Journal, USA Today, and Washington Post.

C. Jarrett Dieterle is a legal policy fellow for the Manhattan Institute.