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 employee of the City of Albuquerque for over seventeen years, was terminated following a series of disciplinary actions related to tardiness, absence, and other performance issues. After taking intermittent Family Medical Leave Act (FMLA) leave to care for her husband and children, the Plaintiff was investigated for work-related issues, leading to her termination. The Plaintiff contested her termination, arguing it was without just cause and violated her due process rights, the FMLA, and her employment contract (paras 2-11).

Procedural History

• District Court of Bernalillo County: Affirmed the personnel board's decision that the City had just cause to terminate the Plaintiff and dismissed Plaintiff’s due process, breach of contract, and FMLA claims on preclusion grounds (para 1).

Parties' Submissions

• Plaintiff: Argued that the personnel board's decision was arbitrary, not in accordance with the law, and not supported by the facts. Contended that the district court erred by dismissing her due process, breach of contract, and FMLA claims on preclusion grounds (para 1).
• Defendants: Asserted that the Court lacks jurisdiction to address the district court’s order affirming the personnel board because the Plaintiff did not file a petition for writ of certiorari pursuant to Rule 12-505. Argued that collateral estoppel or issue preclusion bars Plaintiff from challenging the factual findings of the district court’s order affirming the personnel board (para 16).

Legal Issues

• Whether the Court has jurisdiction to consider Plaintiff’s appeal of the personnel board’s decision.
• Whether the district court erred in concluding that res judicata barred Plaintiff’s breach of contract claim, and collateral estoppel precluded litigating the factual predicates of Plaintiff’s due process and FMLA claims.

Disposition

• The Court held that it lacks jurisdiction to consider Plaintiff’s appeal of the personnel board’s decision due to the untimely filing of a petition for writ of certiorari.
• The Court affirmed the district court's decision that res judicata barred Plaintiff’s breach of contract claim, and collateral estoppel precluded litigating the factual predicates of Plaintiff’s due process and FMLA claims.

Reasons

• The Court found that the Plaintiff did not file a timely petition for writ of certiorari, which is a mandatory precondition for the Court's jurisdiction to review the personnel board’s decision. Consequently, the Court could not address the merits of Plaintiff’s administrative appeal. Regarding the civil complaint, the Court determined that the district court correctly applied collateral estoppel to the personnel board’s decision, preventing the Plaintiff from relitigating issues that were already decided. The Court concluded that the Plaintiff had a full and fair opportunity to litigate her claims during the personnel board hearing, and procedural differences between the actions did not make preclusion unfair (paras 16-37).