AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Plaintiff, previously employed by the Defendant, a public body, sought to pursue a claim under the New Mexico Human Rights Act (NMHRA) arising from her employment. The district court dismissed her complaint based on a statutory exclusion that prohibits individuals employed by a public body from using the New Mexico Civil Rights Act to pursue a claim related to their employment (para 3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellant: Argued that the district court erred in applying the statutory exclusion to her claim, contending that since she is no longer employed by the Defendant, the exclusion should not apply. The Plaintiff interpreted the term "employed" to mean currently employed only, thus excluding her situation from the statutory bar (paras 3-4).
• Defendant-Appellee: [Not applicable or not found]

Legal Issues

• Whether the district court erred in concluding that the statutory exclusion in NMSA 1978, Section 41-4A-3(D) (2021), bars the Plaintiff's claim under the NMHRA, given that her claim arises from her employment with the Defendant, a public body (para 3).
• Whether the term "employed" in the statutory exclusion applies only to individuals currently employed by a public body, thereby not applying to individuals who were previously employed (para 4).

Disposition

• The Court of Appeals affirmed the district court's dismissal of the Plaintiff's complaint under the NMHRA (para 7).

Reasons

• DUFFY, Judge (with JENNIFER L. ATTREP, Chief Judge, and KATHERINE A. WRAY, Judge concurring): The Court found that the district court's determination was based on the plain language of the statutory exclusion, which clearly applies to any claim arising from an individual's employment by a public body, regardless of whether the employment is current or past. The Court rejected the Plaintiff's interpretation of the term "employed" as being limited to current employment, citing precedent that supports the term's applicability to both current and past employment statuses. The Court concluded that adopting the Plaintiff's restrictive view would require reading an unwarranted limitation into the statute, which contradicts the principle of giving effect to clear and unambiguous statutory language without further interpretation (paras 3-6).