Casino Dealers Claim Wynn Tip Pool is Illegal

As discussed here, a group of dealers has sued the Wynn Casino in Las Vegas claiming that Wynn illegally required its dealers to share their tips with managers. One interesting issue raised in this lawsuit is whether the Fair Labor Standards Act imposes any requirements on a tip pool when the employer takes no "tip credit" against the minimum wage. The case is based, in part, on a Department of Labor opinion that, for the first time, takes the position that a tip pool can be invalid even if no tip credit is taken.