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, an engineering consultant employed by Navarro Research & Engineering, Inc., brought a case against Los Alamos National Security, LLC (LANS), alleging discrimination based on sex and national origin, sexual harassment, retaliation under the New Mexico Human Rights Act, and breach of the implied contract of employment and covenant of good faith and fair dealing created by LANS’ personnel policies. The Plaintiff's claims arose from her work at Los Alamos National Laboratory (LANL), managed by LANS, under a contract between Navarro and LANS. The district court granted LANS' motion for summary judgment, concluding that LANS was not the Plaintiff's employer, which was essential to all her claims (paras 1-3, 8-10).

Procedural History

• District Court of Los Alamos County: Granted LANS' motion for summary judgment, dismissing the Plaintiff's complaint based on the conclusion that LANS was not the Plaintiff's employer (para 10).

Parties' Submissions

• Plaintiff-Appellant: Argued that LANS was her employer or joint employer, making it liable for discrimination, sexual harassment, retaliation, and breaches of employment contract and good faith. The Plaintiff presented evidence attempting to show LANS' control over her work and termination (paras 8-9, 18-36).
• Defendant-Appellee (LANS): Contended that there was no employment relationship with the Plaintiff, who was employed exclusively by Navarro. LANS argued that it neither controlled the Plaintiff's work conditions nor had the authority to terminate her employment, thus negating essential elements of all the Plaintiff's claims (paras 9, 18-36).

Legal Issues

• Whether LANS was the Plaintiff's employer or joint employer under the New Mexico Human Rights Act and relevant employment law, making it liable for the alleged discrimination, sexual harassment, retaliation, and breaches of employment contract and good faith (paras 14-37).
• Whether the district court erred in granting summary judgment to LANS based on the conclusion that no employment relationship existed between LANS and the Plaintiff (paras 10-13, 38-41).

Disposition

• The Court of Appeals affirmed the district court's grant of summary judgment and dismissal of the complaint, agreeing with the lower court that LANS was not the Plaintiff's employer or joint employer, which was a necessary element for all of the Plaintiff's claims (para 42).

Reasons

• The Court of Appeals, per Judge Yohalem, concurred with Kristina Bogardus and Katherine A. Wray, JJ., found that:
  An employment relationship between LANS and the Plaintiff was essential for all her claims. The court agreed with the district court that there was no genuine dispute requiring a trial regarding LANS being the Plaintiff's employer or joint employer (paras 1, 14).
  The federal joint employer test, which examines control over employment conditions and the right to terminate employment, did not support the Plaintiff's claim that LANS was her joint employer. The evidence did not demonstrate that LANS had sufficient control over the Plaintiff's work or employment conditions (paras 15-36).
  The Plaintiff's additional claim of an implied contract between LANS and contract workers, which did not require an employment relationship, was not preserved for review on appeal. The Plaintiff did not adequately raise this issue at the district court level for it to be considered on appeal (paras 38-41).