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Facts

  • The New Mexico Department of Public Health (DOH) terminated Abby Maestas from her employment. Following her termination, Maestas appealed through arbitration under the Collective Bargaining Agreement (CBA) and relevant statutes. The arbitrator ruled in favor of Maestas, ordering her reinstatement and awarding back pay from the date of termination until reinstatement. However, when DOH paid the back pay, it deducted amounts Maestas had received in unemployment compensation and disability payments. Maestas contested these deductions, arguing they were improper under the governing statute and regulation (paras 2-3, 6).

Procedural History

  • District Court of Santa Fe County: Confirmed the arbitration award, ordering DOH to reinstate Maestas and pay back pay in accordance with the arbitration award, Section 10-9-18(F), and the CBA (para 5).

Parties' Submissions

  • Petitioner (Maestas): Argued that DOH improperly deducted unemployment compensation and disability payments from her back pay award, contending that the regulation DOH relied upon for the deductions conflicts with the governing statute, which should prevail (para 7).
  • Respondent (DOH): Contended that the deductions were permissible under the regulation since neither the CBA nor the statute specifies the calculation method for back pay, asserting no conflict exists between the regulation, the CBA, and the statute (para 8).

Legal Issues

  • Whether the district court had authority to rule on the motion to compel DOH to pay the full amount of back pay without deductions for unemployment compensation and disability payments (paras 9, 27-32).
  • Whether the appeal should be treated as a petition for writ of certiorari or as a direct appeal (paras 9, 18-26).

Disposition

  • The Court vacated the district court’s order denying the motion to compel full back pay and remanded the matter with instructions to remand the case to the arbitrator for resolution of the back pay dispute (para 32).

Reasons

  • The Court held that the district court did not have the authority to decide the dispute over back pay deductions because the regulation explicitly retained that authority for the arbitrator. The Court emphasized that the substance of the motion, not its title, controls and that the regulation concerning back pay disputes mandates that such disputes remain with the arbitrator. This decision aligns with the state’s strong public policy favoring resolution of disputes through arbitration. Additionally, the Court determined that the appeal was proper as a direct appeal, not a petition for writ of certiorari, based on the district court's exercise of its original jurisdiction in confirming the arbitration award. The Court also allowed the petition for writ of certiorari to be construed as a nonconforming notice of appeal and docketing statement, emphasizing a liberal approach to ensure access to appellate review (paras 13-26, 27-32).
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