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

• Joanne Bachmann was laid off from her position at KNME, a public television station operated by the University of New Mexico (UNM), in October 2009 due to the elimination of her position. Her employment was governed by an implied contract outlined in the UNM Employment Manual. Bachmann's claims against UNM included breach of contract and covenant of good faith and fair dealing, arising from her layoff and the failure to reinstate her to her former position eighteen months later when it was restored (paras 1, 5-13).

Procedural History

• District Court of Bernalillo County: Dismissed all of Bachmann’s claims, ruling that UNM had not breached the terms of Bachmann’s implied contract of employment or the covenant of good faith and fair dealing (para 1).

Parties' Submissions

• Plaintiff-Appellant (Bachmann): Argued that her position was eliminated in retaliation for protected communications about potential misuse of KNME funds by UNM and that the failure to reinstate her breached the terms of her employment contract and the covenant of good faith and fair dealing (paras 10, 11).
• Defendant-Appellee (UNM): Contended that Bachmann’s position was eliminated solely as a cost-saving measure during a severe budget crisis, consistent with the UNM Employee Manual, and that there was no breach of contract or covenant of good faith and fair dealing (para 10).

Legal Issues

• Whether UNM breached Bachmann’s implied contract of employment by failing to reinstate her to the Director of Development position eighteen months after her layoff.
• Whether UNM’s failure to reinstate Bachmann breached the covenant of good faith and fair dealing.

Disposition

• The Court of Appeals affirmed the district court's dismissal of Bachmann’s claims, holding that UNM did not breach the implied contract of employment or the covenant of good faith and fair dealing (paras 2, 3, 31).

Reasons

• The Court of Appeals, per Judge Yohalem, with Judges Medina and Zamora concurring, found that the district court erred in its interpretation of the ambiguous terms of Bachmann’s implied contract without considering the evidence of the parties' intent. However, the appellate court agreed with the district court's conclusion under the right for the wrong reasons doctrine, affirming that UNM did not breach Bachmann’s contract of employment or the covenant of good faith and fair dealing. The court determined that the provision in the UNM Employment Manual regarding reinstatement after layoff was ambiguous but concluded that, based on the uncontroverted evidence at trial regarding the parties' intent, Bachmann was not entitled to reinstatement eighteen months after her layoff. The court also found that the district court's findings of fact justified its judgment that there was no breach of the covenant of good faith and fair dealing, as there was no evidence of bad faith or improper motivation by UNM in not reinstating Bachmann (paras 2-31).