This is a Fair Labor Standards Act and New Mexico Minimum Wage Act overtime case filed in the District of New Mexico on behalf of home health caregivers who alleged they were misclassified as independent contractors and not paid overtime for hours worked above forty in a workweek. The case was filed in August 2022 and resolved in 2025.
What was Golden v. Quality Life Services about?
Named plaintiff Jorge Golden sued Quality Life Services, LLC, along with its owners, alleging that the company classified its home health caregivers as independent contractors and refused to pay overtime when caregivers worked more than forty hours in a workweek. The complaint asserted claims under the Fair Labor Standards Act, 29 U.S.C. § 201 et seq., and the New Mexico Minimum Wage Act, N.M. Stat. § 50-4-22. Mr. Golden brought the federal overtime claim as an opt-in collective action under 29 U.S.C. § 216(b) and the New Mexico claim as a Rule 23 class action.
Where was the case filed?
The case was filed in the United States District Court for the District of New Mexico, Las Cruces Division. The case number is 2:22-cv-00579. The case was filed on August 3, 2022. United States Magistrate Judge Gregory J. Fouratt presided by consent of the parties.
What were the alleged violations?
The complaint alleged that the caregivers were paid on an hourly basis but received no overtime premium for hours worked over forty in a workweek. The complaint also alleged that the caregivers were misclassified as independent contractors rather than employees. Under the federal overtime law, the classification question turns on the economic reality of the working relationship, not on the label the employer assigns. The complaint alleged facts directed at the economic reality test: the company set the work schedule, set the locations, set the pay rate, maintained employment records, and exercised the power to hire and fire.
What is the New Mexico Minimum Wage Act claim?
The New Mexico Minimum Wage Act requires employers to pay employees one and one-half times their regular hourly rate for hours worked over forty in a workweek, paralleling the federal overtime requirement. Because the federal and state claims arose out of the same employment facts, the complaint pursued both side by side, with the federal court exercising supplemental jurisdiction over the New Mexico claim.
How was the case resolved?
The case was resolved in 2025 and terminated on the court's docket on February 10, 2025. The terms of the resolution are not published here, and no settlement amount appears on the public record of the case. This page reports only what the public court record reflects.
Why does this case matter for home health workers?
Home health and personal care workers are one of the categories of workers most often misclassified as independent contractors. The federal overtime protections turn on whether the worker is an employee under the statute, not on whether the worker signed an independent contractor agreement. Cases like Golden illustrate the framework: when caregivers work for an agency that controls the schedule, the patients, the pay, and the manner of the work, the economic reality test is the analytical lens federal courts apply.
Why I file these cases
I file home health misclassification cases because the rules are clear and the workers are the ones who pay the price when they are misapplied. The federal overtime law and the New Mexico Minimum Wage Act both protect caregivers who work over forty hours in a week. Golden is one example of how those protections move through a federal court in New Mexico from filing through resolution.