A New York appellate court has ruled in favor of home health aides who filed complaints against the Department of Labor (DOL) regarding minimum wage violations. The court's decision, issued on June 25, 2026, allows the aides to challenge the DOL's dismissal of their complaints and requires the agency to reopen investigations into their claims. This ruling affects many home health aides who allege they were not compensated fairly under the state's Minimum Wage Act.
The case, known as Matter of Gui Zhu Chen v. Reardon (Docket CV-24-2037 CV-25-0784), centers on complaints filed by home health aides between 2018 and 2022. These aides claimed their employers violated the “13-hour rule,” which permits them to be paid for only 13 hours of a 24-hour shift if they receive eight hours of sleep and three meal breaks. The DOL initially investigated these complaints but later closed the investigations, citing that the aides had other means of relief due to mandatory arbitration clauses in their union contracts.
The aides, represented by the National Center for Law and Economic Justice and The Legal Aid Society, argued that the DOL's decision to close the investigations was a rule that violated the State Administrative Procedure Act (SAPA). They sought to have the DOL's closure annulled and to have their complaints investigated. They also requested class action certification for all home health aides affected by this policy.
The Supreme Court of Albany County ruled in October 2024 that the DOL's closure of the investigations was indeed a rule that had not been properly promulgated under SAPA. The court found that the DOL's policy of closing cases based on the availability of arbitration was applied too generally and without consideration of individual circumstances. In January 2025, the court granted class certification for the aides, limiting it to those whose cases were closed due to the DOL's policy.
The appellate court, with Judges Garry, Ceresia, Powers, and Mackey presiding, upheld the lower court's decision. The judges stated, "The decision to close any and all complaints where the employee was subject to arbitration... was the result of an application of a rule which had not been promulgated in compliance with the dictates of SAPA and was, therefore, subject to annulment." This ruling emphasizes the importance of proper procedures in administrative rule-making and the rights of employees to seek redress for wage violations.
The court's ruling has significant implications for home health aides across New York. It reinforces the idea that employees should not be denied the right to have their complaints investigated simply because they are subject to arbitration agreements. The decision also highlights the need for the DOL to follow proper procedures when implementing policies that affect workers' rights.
Going forward, the DOL will need to revisit its policies regarding the investigation of wage complaints, especially for those employees with arbitration clauses in their contracts. This ruling may encourage more home health aides to come forward with their complaints, knowing that their cases will be taken seriously and investigated appropriately.
As for the future of this case, there is the possibility of further appeals. The DOL may seek to challenge this ruling in a higher court. However, details on any potential next steps were not available in the court filing. The outcome of this case could set a precedent for how similar complaints are handled in the future.