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, employed as a physician's assistant, filed a complaint against her employer, alleging a violation of the New Mexico Human Rights Act. The employer sought dismissal based on a forum-selection clause in the employment contract, which designated Maricopa County, Arizona, as the exclusive jurisdiction for disputes. The district court dismissed the Plaintiff's complaint, agreeing with the employer's argument (paras 3-4).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff: Argued that the employer violated the New Mexico Human Rights Act and contested the application of the forum-selection clause, citing a statutory provision barring such clauses in agreements for clinical health care services. The Plaintiff also argued that the contract was illusory and unenforceable (paras 3, 5).
• Defendants: Argued for the dismissal of the complaint based on the forum-selection clause in the employment contract, which designated Arizona as the exclusive jurisdiction for disputes. They also contended that the claims against the supervisor, Ashley Gudgel, fell within the scope of the forum-selection clause (paras 3, 7).

Legal Issues

• Whether the forum-selection clause in the employment contract, designating Arizona as the exclusive jurisdiction for disputes, is enforceable against the Plaintiff's complaint alleging a violation of the New Mexico Human Rights Act.
• Whether the district court erred in dismissing the claims against the Plaintiff's supervisor, Ashley Gudgel, based on the forum-selection clause.

Disposition

• The Court of Appeals affirmed the district court's order dismissing the Plaintiff's complaint (para 8).

Reasons

• J. Miles Hanisee, Judge (Jacqueline R. Medina, Judge and Briana H. Zamora, Judge concurring): The Court found that the forum-selection clause was enforceable, as it clearly designated Arizona as the exclusive jurisdiction for disputes and did not violate New Mexico public policy. The Court also determined that Arizona's Human Rights Act, like New Mexico's, prohibits employment discrimination based on disability, thus not offending New Mexico public policy. The Plaintiff's reliance on a statutory provision barring forum-selection clauses in agreements for clinical health care services was found inapplicable, as the provision was not effective at the time the contract was entered into and did not cover the Plaintiff's role. Additionally, the Court agreed with the district court's conclusion that the contract was not illusory and that the claims against the supervisor, Ashley Gudgel, were appropriately dismissed under the forum-selection clause, as there were no allegations of her acting outside her employment scope (paras 2-7).