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

• From 2004 to 2012, the Plaintiff was enrolled in the Defendant's doctoral program in Materials Engineering. Conflicts with his doctoral committee culminated a week before his planned dissertation defense. Despite passing the defense, the committee raised concerns about his knowledge, leading to his termination from the program after he allegedly made threats against committee members, which he denied. Following an unsuccessful appeal of his termination, the Plaintiff filed a civil rights complaint and a federal lawsuit, which was dismissed. A settlement was reached where the Plaintiff agreed not to sue in exchange for $6000 and the removal of termination references from his academic file. The Plaintiff later sued the Defendant in state court for breach of contract and punitive damages, claiming the Defendant breached the settlement by not removing a termination letter from his academic records (paras 2-4).

Procedural History

• District Court of Socorro County: The Plaintiff's claim was dismissed with prejudice for failure to state a claim upon which relief may be granted, finding it barred by governmental immunity (para 1).

Parties' Submissions

• Plaintiff: Argued that the PhD application process constituted an implied-in-fact contract between him and the Defendant, which should defeat governmental immunity (para 7).
• Defendant: Contended that the Plaintiff's complaint did not allege the existence of a writing sufficient to defeat governmental immunity, emphasizing the absence of any written contract between the parties that could support the Plaintiff's claim (para 7).

Legal Issues

• Whether the district court erred in dismissing the Plaintiff's claim for breach of contract on the grounds of governmental immunity (para 6).
• Whether an implied-in-fact contract exists between the parties and if such a contract is sufficient to defeat governmental immunity (para 9).

Disposition

• The Court of Appeals affirmed the district court's decision to dismiss the Plaintiff's claim (para 1).

Reasons

• B. Zamora, J., with Jacqueline R. Medina, J., and Shammara H. Henderson, J., concurring, held that the Plaintiff failed to adequately plead the existence of an implied-in-fact contract and that even if such a contract existed, it would not be sufficient to defeat governmental immunity under Section 37-1-23(A). The court emphasized that governmental entities are immune from actions based on contract except those based on a valid written contract. The court found that the Plaintiff's claim did not assert the existence of a writing memorializing a contract between the parties. The court also noted that the confirmation receipt and the online application process cited by the Plaintiff did not constitute assenting conduct or promissory language sufficient to establish an implied-in-fact contract. The court concluded that the district court did not err in granting the Defendant's motion to dismiss pursuant to Rule 1-012(B)(6) (paras 6-15).