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Decision Information

Citations - New Mexico Laws and Court Rules
Rule Set 11 - Rules of Evidence - cited by 2,363 documents

Decision Content

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 former employee, sued the Defendants, her former employer and its owner, alleging workplace sexual harassment, gender discrimination, and violations of the New Mexico Human Rights Act (NMHRA). The jury found in favor of the Plaintiff on the hostile work environment claim but in favor of the Defendants on the retaliation and battery claims. The district court awarded attorney fees and costs to the Plaintiff.

Procedural History

  • [Not applicable or not found]

Parties' Submissions

  • Plaintiff: Argued that the district court erred by granting partial summary judgment on her NMHRA retaliation claim, improperly allowing inspection of her home, and incorrectly instructing the jury on her retaliation claim.
  • Defendants: Contended that the district court erred in instructing the jury on the apportionment of liability, allowing evidence of Defendants' wealth, admitting testimony and text messages from a third party, admitting evidence of racial slurs, admitting a summary exhibit under Rule 11-1006 NMRA, and in calculating attorney fees using the lodestar method.

Legal Issues

  • Whether the district court erred in granting partial summary judgment on the Plaintiff's NMHRA retaliation claim.
  • Whether the district court improperly allowed Defendants' request to inspect Plaintiff's home.
  • Whether the district court incorrectly instructed the jury on the Plaintiff's retaliation claim.
  • Whether the district court erred in its instructions on the apportionment of liability between Defendants.
  • Whether the district court improperly admitted evidence regarding Defendants' wealth, third-party testimony and text messages, use of racial slurs, and a summary exhibit under Rule 11-1006 NMRA.
  • Whether the district court erred in calculating attorney fees using the lodestar method.

Disposition

  • The appellate court affirmed the district court's decisions on all issues raised by both the Plaintiff and the Defendants.

Reasons

  • The appellate court found no reversible error in the district court's rulings. It held that the district court did not err in granting summary judgment on the Plaintiff's retaliation claim, as the alleged retaliatory actions did not constitute an "adverse employment action" under NMHRA standards (paras 5-11). The court also found no abuse of discretion in the district court's decision to allow inspection of the Plaintiff's home (para 12) or in its jury instructions regarding the Plaintiff's retaliation claim (paras 13-20). Regarding the Defendants' cross-appeal, the court found that the jury instructions on apportionment of liability were proper, the admission of evidence regarding Defendants' wealth and other contested evidentiary issues were within the district court's discretion, and the calculation of attorney fees using the lodestar method was not an abuse of discretion (paras 21-52).
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