A Texas state court judge's letter ruling temporarily enjoins San Antonio's paid sick and safe leave ordinance from taking effect on December 1, 2019. While the November 22, 2019 ruling says a trial on the merits will occur "as soon as possible," it does not set a trial date.

Though businesses with San Antonio operations have received a last-minute reprieve from compliance, relief may be temporary. Accordingly, companies that did not announce or implement policies and procedures in advance of the law's December 1 start date may want to consider continuing to "hold" the rollout process until litigation resolves the questions raised about the law's validity. For employers that did not hold back policies and procedures, limited time remains—particularly given the upcoming Thanksgiving holiday—to determine whether rollout will continue in light of the injunction and, if not, how to explain that business decision to employees. Employers should consider consulting knowledgeable employment counsel about how this development affects operations.

We will continue to monitor the litigation and share relevant future developments.