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 former president of Santa Fe Community College, sued the College and its Board of Directors for breach of contract, breach of the implied covenant of good faith and fair dealing, and promissory estoppel. This action followed the College's report to the New Mexico Educational Retirement Board (ERB), which led to a reduction in the Plaintiff's retirement benefits. The College's initial report to ERB, and subsequent correction, did not prevent the ERB from requesting a downward revision of the Plaintiff's eligibility withholdings, ultimately reducing her retirement benefit. The Plaintiff's retirement benefit was permanently reduced due to the College's errors in calculating and reporting her salary (paras 2-3).

Procedural History

• District Court of Santa Fe County: The district court dismissed the Plaintiff's claims, finding that the Plaintiff failed to file her complaint within the statute of limitations and the complaint failed to state a claim upon which relief could be granted (para 1).

Parties' Submissions

• Plaintiff: Argued that the discovery rule should apply, meaning the statute of limitations would start from when she discovered or should have discovered the facts forming the basis for her claims. She contended that her claims did not accrue until she received the ERB’s audit report, which attributed the reduction in her retirement benefits to the College’s faulty reporting (paras 6, 8-9).
• Defendants: Maintained that the Plaintiff’s claims were barred by the two-year statute of limitations set forth in Section 37-1-23(B). They argued that the Plaintiff's complaint was untimely because the statute of limitations began to run no later than August 2013, when the Plaintiff received notification from ERB of changes in her retirement benefit (para 8).

Legal Issues

• Whether the discovery rule applies to the Plaintiff’s claims, potentially invoking the statute of limitations from the time of discovery rather than the occurrence of the event (para 6).
• Whether the Plaintiff’s complaint states a claim upon which relief could be granted for breach of contract, breach of the implied covenant of good faith and fair dealing, and promissory estoppel (para 10).

Disposition

• The Court of Appeals reversed the district court’s order dismissing the Plaintiff’s amended complaint and remanded for further proceedings (para 19).

Reasons

• The Court of Appeals, per WRAY, J., with MEDINA, J., and YOHALEM, J., concurring, found that the discovery rule applies to the Plaintiff’s claims, making the resolution of its application a matter for the jury. The court held that the Plaintiff sufficiently pleaded the asserted claims, invoking the discovery rule based on when she discovered or should have discovered the facts forming the basis for her claims. The court concluded that the Plaintiff’s complaint provided sufficient allegations to give the Defendants fair notice of the claims asserted, allowing them to adequately respond. The court separately analyzed and found sufficient grounds for the claims of breach of contract, breach of the implied covenant of good faith and fair dealing, and promissory estoppel, based on the allegations in the amended complaint (paras 5-18).