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 filed a lawsuit against his employer, the Department, and two supervisors, alleging employment discrimination, including retaliation for filing a complaint. The Defendants sought to subpoena tax-related documents from the Plaintiff's wife, Schneider, who was not a party to the action, to demonstrate alleged irregularities in gross receipts returns filed by Schneider's law practice as evidence of the claimed retaliation (paras 3-4).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendants: Argued that subpoenas should be issued to Schneider and the Department for tax-related documents to support their defense against the Plaintiff's claims of retaliation (para 4).
• Schneider: Contended that her gross receipts tax information was privileged and confidential under the Tax Administration Act and Rule 11-502, thus should not be disclosed in response to the Defendants' subpoenas (para 5).

Legal Issues

• Whether the Tax Administration Act and Rule 11-502 NMRA protect Schneider's gross receipts tax information from being disclosed through subpoenas issued in the case (para 1).
• Whether Schneider has waived her rights or the privilege against disclosure of her tax information (para 2).

Disposition

• The Court of Appeals reversed the district court's order permitting the subpoenas and remanded to quash the subpoenas (para 2).

Reasons

• The Court found that the Tax Administration Act and Rule 11-502 NMRA create an evidentiary privilege that protects Schneider's gross receipts tax information from disclosure. The Court held that Schneider did not waive her rights or the privilege against disclosure. The Court reasoned that the Act's taxpayer confidentiality provisions and the evidentiary privilege recognized by Rule 11-502 barred discovery of Schneider's tax information by way of the subpoenas issued in this case. The Court also noted that the procedural history and the parties' submissions indicated a clear dispute over the applicability of the privilege and the confidentiality of tax information, leading to the conclusion that Schneider's tax information was protected from disclosure (paras 7-34).