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 employee of the Defendant, a college, was removed from her position as director of a campus and later terminated. This action followed her communications to the college's administrators regarding the college's failure to approve necessary expenditures for a campus revitalization project, which she argued jeopardized federal funding and the project's success. The Plaintiff sued the Defendant under the New Mexico Whistleblower Protection Act (WPA), claiming retaliation for her protected conduct of raising concerns about the misuse of funds and gross mismanagement.

Procedural History

• District Court of Rio Arriba County: The jury found in favor of the Plaintiff, awarding damages for back pay and emotional distress, and the court ordered the Defendant to reinstate the Plaintiff. The court denied the Defendant's motion for a new trial, remitted the damages awards, and denied the Plaintiff's request for post-judgment interest on the back pay.

Parties' Submissions

• Plaintiff: Argued that her removal and termination were retaliatory actions by the Defendant in response to her protected conduct under the WPA. She communicated to the Defendant's administrators about the college's failure to approve necessary expenditures for the campus revitalization project, risking federal funding and the project's success.
• Defendant: Contended that the Plaintiff's communications were not protected under the WPA and that her removal and termination were based on legitimate business reasons, including poor performance and a reduction in force, not retaliation.

Legal Issues

• Whether the Plaintiff's communications to the Defendant's administrators constituted protected conduct under the WPA.
• Whether the Defendant's actions in removing the Plaintiff from her position and terminating her employment constituted retaliation under the WPA.
• Whether the district court erred in ordering remittitur of the jury's damages awards.
• Whether the Plaintiff is entitled to post-judgment interest on the back pay award.

Disposition

• The appellate court reversed the remittitur and post-judgment interest orders but otherwise affirmed the district court's decisions.

Reasons

• The appellate court found substantial evidence supporting the jury's verdict that the Plaintiff engaged in protected conduct by communicating concerns about the misuse of funds and gross mismanagement, and that the Defendant retaliated against her for this conduct. The court held that the WPA protects such communications and that the evidence supported a finding of retaliation. Regarding the remittitur, the court concluded that the jury's awards for back pay and emotional distress were not so grossly out of proportion as to shock the conscience, thus reversing the district court's order for remittitur. The court also held that the WPA explicitly provides for interest on back pay awards, thereby waiving sovereign immunity for post-judgment interest, and reversed the district court's denial of the Plaintiff's request for post-judgment interest on the back pay.