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 working at Outback Steakhouse, injured his ankle and reported the injury to his supervisor, Dustin York. Despite the injury, York discouraged the Plaintiff from filing a worker's compensation claim and delayed submitting the claim, which slowed the availability of Plaintiff's benefits. After insisting on filing the claim, Plaintiff was informed he would no longer be promoted due to being perceived as "unreliable." Plaintiff's requests for accommodation upon his return were refused by York, and approximately five weeks post-injury, after contacting Outback's employment paralegal about York's actions, Plaintiff was terminated (paras 2-5).

Procedural History

• District Court of Doña Ana County: Jury found that Outback violated the New Mexico Human Rights Act (NMHRA) by retaliating against the Plaintiff for filing a worker's compensation claim, awarding damages for lost wages and emotional distress (para 9).
• Certiorari Dismissed, January 13, 2020, No. S-1-SC-37873.

Parties' Submissions

• Plaintiff-Appellee: Argued that Outback unlawfully discriminated against him based on his disability or perceived disability and retaliated against him for filing a worker's compensation claim. Also alleged common law tort claims for retaliatory discharge and negligent hiring, training, supervision, and retention of York (para 6).
• Defendant-Appellant: Contended that the Plaintiff's worker's compensation claim does not provide a basis for an NMHRA claim, that Plaintiff failed to establish a reasonable belief of being disabled, and that inconsistent rulings deprived Outback of a fair jury determination regarding Plaintiff's disability status (para 1).

Legal Issues

• Whether the Plaintiff's previously filed worker's compensation claim provides a basis for his NMHRA claim that Outback retaliated against him.
• Whether the Plaintiff established a reasonable, objective, good-faith belief he was disabled, or Outback believed him to be disabled, when it terminated his employment.
• Whether inconsistent evidentiary and legal rulings by the trial court deprived Outback of a fair jury determination as to whether Plaintiff was disabled.

Disposition

• The Court of Appeals affirmed the district court’s judgment and certain pre- and posttrial rulings associated with the jury’s finding that Outback violated the NMHRA (para 13).

Reasons

• The Court of Appeals found that Outback regarded the Plaintiff as disabled when it retaliated against him for opposing its unlawful discriminatory practice, thus violating the NMHRA. The court concluded that Plaintiff established Outback regarded him to be physically handicapped as that term is utilized in the NMHRA, based on the evidence presented at trial, including testimony from York, Plaintiff's supervisor. The court also determined that Plaintiff had a good faith, objectively reasonable belief that Outback violated the NMHRA. The court declined to address whether filing a worker's compensation claim could be a basis for liability under the NMHRA, as the jury's verdict was legally sustainable on the theory advanced by Plaintiff. The court also noted that Outback either acquiesced to or waived objections to the jury instructions and special verdict form, which became the law of the case (paras 19-40).