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

• Eight named inmates and two nonprofit organizations filed an amended complaint in district court, alleging that the State of New Mexico's management of COVID-19 in prisons violated inmates' rights under the New Mexico Constitution. They claimed the state allowed COVID-19 to spread by not enforcing mandates for social distancing, mask-wearing, heightened hygiene, and safe quarantine and treatment. The plaintiffs sought a classwide writ of habeas corpus and classwide injunctive and declaratory relief for all current and future persons held in New Mexico prison facilities during the COVID-19 pandemic (paras 1, 3-4).

Procedural History

• District Court: The district court dismissed the amended complaint, concluding it lacked subject-matter jurisdiction because the named plaintiffs failed to exhaust the internal grievance procedures of the New Mexico Corrections Department (NMCD) before seeking relief, as required by NMSA 1978, Section 33-2-11(B) (1990) (para 1).

Parties' Submissions

• Plaintiffs-Appellants: Argued that the district court erred in concluding that the exhaustion requirement under Section 33-2-11(B) is jurisdictional, contended that no futility exception applies was an error because a material factual dispute exists as to whether exhaustion is futile, and claimed the district court erred in dismissing the nonprofit organizations on the basis that the grievance process applies only to inmates (paras 10, 12, 13, 20, 22, 26, 36, 42, 50).
• Defendants-Appellees: Moved to dismiss, arguing that the district court lacked subject-matter jurisdiction because the named plaintiffs failed to exhaust administrative remedies under Section 33-2-11(B) (para 6).

Legal Issues

• Whether the exhaustion requirement under Section 33-2-11(B) is jurisdictional for habeas corpus claims and other claims under the New Mexico Constitution (para 10).
• Whether the district court erred in holding that no futility exception applies to the exhaustion requirement (para 10).
• Whether the district court erred in dismissing the nonprofit organizations on the basis that the grievance process applies only to inmates (para 10).

Disposition

• The Supreme Court of New Mexico affirmed the district court's dismissal of the amended complaint, holding that Section 33-2-11(B) imposes a jurisdictional exhaustion requirement for statutorily created rights but not for habeas corpus claims. However, Rule 5-802(C) imposes an independent duty to exhaust administrative remedies for habeas claims. The court also held that to satisfy the habeas corpus exhaustion requirement under Rule 5-802(C) for an entire plaintiff class, one or more named class members must exhaust administrative remedies for each claim. Since no named plaintiff exhausted or sought to exhaust NMCD’s internal grievance procedures, and no facts were alleged to show exhaustion would be futile, the dismissal was affirmed (paras 2, 19, 22, 35, 44, 53).

Reasons

• The court reasoned that while Section 33-2-11(B)’s exhaustion requirement is jurisdictional for statutorily created rights, it does not apply to habeas corpus claims. However, Rule 5-802(C) requires exhaustion of administrative remedies for habeas claims related to conditions of confinement. The court rejected the plaintiffs' arguments that exhaustion was futile because the NMCD could not grant the relief requested (release), stating that the plaintiffs did not allege facts sufficient to show that exhaustion would be futile. The court also held that allowing the nonprofit organizations to pursue claims when the named plaintiffs had not exhausted their administrative remedies would frustrate the legislative purpose of Section 33-2-11(B) and Rule 5-802(C) (paras 12-14, 20-22, 26, 33, 42-43, 50).