State Ex Rel. Stalter v. NCO Fin. Sys., Inc.

New Mexico Court of Appeals·Decided May 27, 2026·Published

Opinion

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1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO 2 Opinion Number: __________ 3 Filing Date: May 27, 2026 4 No. A-1-CA-42148

5 STATE OF NEW MEXICO ex rel. 6 KENNETH STALTER,

7 Plaintiff-Appellant, 8 v.

9 NCO FINANCIAL SYSTEMS, INC. 10 d/b/a TRANSWORLD SYSTEMS, INC.; 11 WINDHAM PROFESSIONALS, INC.; 12 WILLIAMS & FUDGE, INC.; TODD, 13 BREMER & LAWSON, INC.; IMMEDIATE 14 CREDIT RECOVERY, INC.; CONTINENTAL 15 SERVICE GROUP, INC. d/b/a CONSERVE; 16 ALLTRAN EDUCATION, INC.; COLLECTO 17 d/b/a EOS CCA; ENTERPRISE RECOVERY 18 SYSTEMS, INC.; and NATIONAL CREDIT 19 MANAGEMENT CORPORATION,

20 Defendants-Appellees.

21 APPEAL FROM THE DISTRICT COURT OF BERNALILLO COUNTY 22 Denise Barela Shepherd, District Court Judge

23 Fitzpatrick Law, LLC 24 Sean M. Fitzpatrick 25 Albuquerque, NM

26 for Appellant 1 Modrall Sperling Roehl Harris & Sisk, P.A. 2 Jennifer G. Anderson 3 Elizabeth A. Martinez 4 Albuquerque, NM

5 for Appellees NCO Financial Systems, Inc., d/b/a Transworld Systems Inc., 6 Windham Professionals, Inc., Williams & Fudge, Inc., Todd, Bremer & Lawson, 7 Inc., Immediate Credit Recovery, Inc., Continental Service Group, Inc., d/b/a/ 8 ConServe, Alltran Education, Inc., Collecto d/b/a EOS CCA, Enterprise Recovery 9 Systems, Inc., and National Credit Management Corporation

10 Frost Echols LLC 11 David A. Grassi, Jr. 12 Chad V. Echols 13 Rock Hill, SC

14 for Appellees Windham Professionals, Inc., Williams & Fudge, Inc., and Todd, 15 Bremer & Lawson, Inc.

16 Lippes Mathias LLP 17 Brenden H. Little 18 Sean M. O’Brien 19 Buffalo, NY

20 for Appellee Continental Service Group, Inc., d/b/a/ ConServe 1 OPINION 2 YOHALEM, Judge. 3 {1} This is an appeal from the district court’s dismissal of Plaintiff Kenneth 4 Stalter’s (Relator) qui tam complaint alleging violations of the Fraud Against 5 Taxpayers Act (FATA), NMSA 1978, §§ 44-9-1 to -14 (2007, amended 2015). 6 Relator’s complaint alleges that each of the ten debt collection agencies named as 7 Defendants 1 in the complaint (collectively, Defendants) violated FATA by making 8 false or fraudulent statements, which misrepresented they were in compliance with 9 all state laws governing debt collection (1) to the New Mexico Regulatory and 10 Licensing Division (RLD) to fraudulently obtain a business license to collect debt in 11 New Mexico; and (2) to state educational and health institutions (collectively, State 12 Institutions) to fraudulently obtain well-paying contracts to collect past-due accounts 13 for these institutions. We affirm the district court’s dismissal under Rule 1-012(B)(6) 14 NMRA of Relator’s first cause of action under FATA for failure to state a claim, and 15 reverse the district court’s dismissal of Relator’s second cause of action under 16 FATA, concluding that Relator has adequately pleaded his second FATA claim that

1

NCO Financial Systems, Inc. d/b/a Transworld Systems Inc. (NCO);

Windham Professionals, Inc.; Williams & Fudge, Inc.; Todd, Bremer & Lawson, Inc.; Immediate Credit Recovery, Inc.; Continental Service Group, Inc., d/b/a ConServe; Alltran Education, Inc.; Collecto d/b/a EOS CCA; Enterprise Recovery Systems, Inc.; and National Credit Management Corporation.

1 Defendants have knowingly made a false or fraudulent claim for payment or 2 approval of payment from state funds under Section 44-9-3(A)(2) of FATA. 3 BACKGROUND 4 FATA’s History and Purpose 5 {2} FATA “imposes civil liability for knowingly presenting a false or fraudulent 6 claim for payment to the [s]tate.” Galloway v. N.M. Off. of Superintendent of Ins., 7 2025-NMSC-012, ¶ 1, 572 P.3d 855. The civil action authorized by FATA, known 8 as a qui tam action, allows a private party, called a relator, to pursue a claim for fraud 9 against the state in return for a share of the proceeds or penalties recovered on the 10 state’s behalf. See id. “A qui tam action arises only by statute, specifically 11 authorizing a private party to sue on behalf of the government.” State ex rel. 12 Balderas v. Bristol-Myers Squibb Co., 2019-NMCA-016, ¶ 2, 436 P.3d 724; see 13 §§ 44-9-5 to -7 (authorizing private parties to sue on behalf of the government). New 14 Mexico’s qui tam statute is similar to the federal False Claims Act (FCA), 31 U.S.C. 15 §§ 3729-3733, which was first enacted during the civil war to stem fraud by defense 16 contractors who were gouging the Northern armies by over-pricing goods and 17 services. See Galloway, 2025-NMSC-012, ¶¶ 9-10. 18 {3} Like the FCA, FATA’s purpose is to “compensate[] the [s]tate for losses 19 incurred as a result of fraud and encourage[] qui tam plaintiffs to bring civil actions 20 to root out fraud.” State ex rel. Foy v. Austin Cap. Mgmt., Ltd., 2015-NMSC-025, 1 ¶ 31, 355 P.3d 1. Because there is little New Mexico precedent construing FATA, 2 we often turn to federal precedent construing comparable FCA provisions for 3 guidance. See Foy, 2015-NMSC-025, ¶ 16 (“We find the cases construing FATA’s 4 federal analogue, the [FCA], helpful in understanding the context and purpose of 5 FATA.”). 6 Relator’s Qui Tam Complaint 7 {4} Relator filed a qui tam complaint in May 2022, and a first amended complaint 8 on November 10, 2023, 2 alleging that Defendants fraudulently claimed to be in 9 compliance with all provisions of state and federal law governing debt collection 10 agencies, knowing that they were not complying and did not intend to comply with 11 at least three requirements imposed by the New Mexico Collection Agency 12 Regulatory Act (CARA), NMSA 1978, §§ 61-18A-1 to -33 (1987, amended 2022): 13 (1) that “[e]very licensed office of a collection agency, whether a principal or branch 14 office, shall be under the active charge of a licensed manager,” § 61-18A-22(A); (2) 15 that the licensed manager employed by the collection agency shall be “physically 16 present at the licensee’s office at least 75 percent of the time during which the office 17 is open for business,” § 61-18A-22(B); and (3) that every licensed foreign collection 18 agency “shall establish and maintain a collection agency in New Mexico at all times

2

We refer throughout this opinion to the first amended complaint.

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