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, a tenure-track mechanical engineering professor, was employed by the Defendant, New Mexico Institute of Mining and Technology, under a series of written one-year contracts. The most recent contract covered the academic year from August 8, 2011, to May 11, 2012. On April 2, 2012, the Defendant informed the Plaintiff that his contract would not be renewed, and he was directed to surrender all property belonging to the Defendant by May 11, 2012. The Plaintiff continued working until the specified date.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff: Argued that the Defendant wrongfully terminated him in violation of the employment contract, which was reinforced by written personnel practices, policies, and procedures, creating a reasonable expectation of continued employment with discharge only for good cause. The Plaintiff also referenced a document titled "Regulations Governing Academic Freedom and Tenure" to support his claim of wrongful discharge based on breach of contract (paras 3, 5, 22).
• Defendant: Moved for summary judgment based on two theories of sovereign immunity under NMSA 1978, Section 37-1-23 (1976), arguing that the Plaintiff's claim was time-barred and not based on a valid written contract. The Defendant contended that the claim accrued on April 2, 2012, when the Plaintiff was notified of the nonrenewal, and that the Plaintiff failed to allege a breach of a specific contractual term (paras 4, 5).

Legal Issues

• Whether the Plaintiff's claim for wrongful discharge by breach of contract was time-barred under Section 37-1-23(B).
• Whether the Plaintiff's claim was based on a valid written contract as required by Section 37-1-23(A).

Disposition

• The district court's denial of the Defendant's motion for summary judgment was affirmed.

Reasons

• The Court found that the Plaintiff's wrongful discharge claim was timely filed within two years from the date of actual termination, which was the accrual date of the claim, not from the date of notice of nonrenewal. The Court also determined that the Plaintiff's claim was based on a valid written contract, as the employment contract and the referenced "Regulations Governing Academic Freedom and Tenure" could constitute a valid written contract under Section 37-1-23(A). The Court concluded that the district court did not err in denying the Defendant's motion for summary judgment on both grounds of sovereign immunity (paras 8-29).