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, while employed at Hume & Associates, LLC, submitted sworn declarations to the United States Department of Commerce alleging misconduct by Defendant Robert in representing New Mexico garlic farmers and Chinese companies. In retaliation, Defendants filed claims against the Plaintiff in magistrate court, which were later dismissed and refiled as counterclaims in district court. The counterclaims included allegations of financial improprieties and a breach of duty of loyalty by the Plaintiff (paras 2-3).

Procedural History

• District Court of Taos County: Denied Plaintiff's motion to dismiss Defendants' counterclaims under the Anti-SLAPP statute and Plaintiff's request for Rule 1-011 NMRA sanctions.

Parties' Submissions

• Plaintiff: Argued that Defendants' counterclaims were retaliatory for her participation in federal proceedings and thus should be dismissed under the Anti-SLAPP statute. Additionally, requested sanctions against Defendants for improper purpose and untrue statements underlying their claims (para 4).
• Defendants: Challenged the appellate court's jurisdiction to hear the appeal, contending that the Anti-SLAPP statute does not apply to participation in federal proceedings and that the appeal does not proceed from a final order (para 7).

Legal Issues

• Whether the Court of Appeals has jurisdiction to review the district court’s denial of Plaintiff’s special motion under the Anti-SLAPP statute (para 6).
• Whether the district court erred in denying Plaintiff’s special motion under the Anti-SLAPP statute (para 6).
• Whether the district court erred in denying Plaintiff’s motion for sanctions under Rule 1-011 NMRA (para 6).

Disposition

• The Court of Appeals affirmed the district court's order denying Plaintiff's motion to dismiss under the Anti-SLAPP statute and declined to review the district court's order denying Plaintiff's request for sanctions (para 28).

Reasons

• The Court of Appeals held that it had jurisdiction over the appeal, interpreting the Anti-SLAPP statute to allow for an expedited appeal from a trial court order on special motions, regardless of whether the order was final or addressed the applicability of the Anti-SLAPP statute to the conduct or speech at issue (paras 8-15). The Court further held that the Anti-SLAPP statute does not protect participation in federal proceedings, as the statute explicitly applies to conduct or speech in connection with proceedings before a political subdivision of the state. Therefore, the district court did not err in denying Plaintiff's special motion on this basis (paras 16-23). The Court declined to address Plaintiff's argument regarding the duty-of-loyalty counterclaim not being exclusively directed to the Department of Commerce due to lack of preservation and declined to review the district court's denial of sanctions due to the absence of jurisdictional argument from Plaintiff (paras 24-27).