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 post-doctoral fellow and resident physician at the University of New Mexico School of Medicine, was terminated from the residency program. She alleged that her termination was due to discrimination and retaliation following her report of being raped by a senior resident in the program. The Plaintiff claimed violations under the New Mexico Human Rights Act (HRA), the Whistleblower Protection Act (WPA), the New Mexico Tort Claims Act (TCA), and for breach of contract (paras 1, 5-6).

Procedural History

• District Court of Bernalillo County: Dismissed Plaintiff’s TCA and WPA claims, granted summary judgment in favor of Defendant on Plaintiff’s breach of contract claim, and allowed HRA claims to proceed to jury, which found in favor of Defendant (paras 2-3).
• Court of Appeals of New Mexico: Reversed district court’s dismissal of Plaintiff’s WPA claims, affirmed the district court on remaining issues, and reversed the district court’s denial of costs associated with Defendant’s electronic filing fees (paras 3-4, 69-70).

Parties' Submissions

• Plaintiff: Argued that her termination was due to discrimination and retaliation in violation of the HRA, WPA, and breached her contract under the TCA. She also claimed the district court erred in its jury instructions on her HRA claim (paras 1, 3).
• Defendant: Argued for dismissal of Plaintiff’s WPA and TCA claims, summary judgment on the breach of contract claim, and that the HRA provided the exclusive remedy for Plaintiff’s retaliation claim. Defendant also cross-appealed for costs and attorney fees (paras 3-4, 13, 58).

Legal Issues

• Whether the district court erred in dismissing Plaintiff’s WPA claims on the grounds that the WPA and HRA are irreconcilably conflicting.
• Whether the district court erred in granting summary judgment in favor of Defendant on Plaintiff’s breach of contract claim.
• Whether the district court erred in its jury instructions on Plaintiff’s HRA claim.
• Whether the district court erred in denying Defendant’s requested costs and attorney fees (paras 3-4, 18-19, 58).

Disposition

• Reversed the district court’s dismissal of Plaintiff’s WPA claims.
• Affirmed the district court on all other issues raised by Plaintiff.
• Reversed the district court’s denial of costs associated with Defendant’s electronic filing fees.
• Affirmed the district court on remaining issues regarding costs and attorney fees (paras 69-70).

Reasons

• The Court of Appeals found that the district court erred in dismissing Plaintiff’s WPA claims based on a perceived irreconcilable conflict with the HRA, citing statutory language and precedents that support the coexistence of claims under both statutes. The Court affirmed the district court’s summary judgment on the breach of contract claim, finding no evidence that Plaintiff was prevented from completing the grievance procedure required by her contract. The Court also upheld the district court’s jury instructions and its decisions on costs and attorney fees, except for the denial of electronic filing fees, which was reversed due to a misinterpretation of the applicable rules (paras 25-28, 43-44, 52-56, 62-63).