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

• Three former inmates of the Camino Nuevo Correctional Center were sexually assaulted by Anthony Townes, a corrections officer employed by the Corrections Corporation of America (CCA), which operated the prison. Townes exploited his position and the prison's policies to facilitate these assaults, including manipulating access through controlled areas and utilizing surveillance blind spots. The assaults were enabled by the prison's lax enforcement of rules designed to protect inmates from such abuse (paras 2-4).

Procedural History

• United States District Court: Found Townes liable for compensatory damages under both § 1983 and state tort law for the intentional torts of sexual assault and false imprisonment. Declined to hold CCA and Wagner vicariously liable for Townes' actions but ruled they could be liable for negligence in supervising Townes. The jury found CCA and Wagner liable for negligent supervision regarding Plaintiffs Spurlock and Carrasco but not for Plaintiff Carrera (paras 6-9).
• United States Court of Appeals for the Tenth Circuit: Certified a question to the Supreme Court of the State of New Mexico regarding the applicability of comparative fault in reducing damages for negligent supervision claims in the context of an inmate sexually assaulted by a corrections officer (para 10).

Parties' Submissions

• Plaintiffs-Appellants/Cross-Appellees: Argued that the Corrections Corporation of America and Warden Barbara Wagner should be vicariously liable for the damages caused by Anthony Townes' intentional torts, as these were facilitated by the authority and environment provided by the prison (N/A).
• Defendants-Appellees/Cross-Appellants: Contended that they should not be held vicariously liable for Townes' actions, which they deemed outside the scope of his employment. They argued for the applicability of comparative fault to potentially reduce the damages awarded for their negligent supervision.

Legal Issues

• Whether a private prison and its warden are vicariously liable under New Mexico law for damages caused by the intentional torts of an on-duty corrections officer who sexually assaulted inmates.
• Whether the affirmative defense of comparative fault applies in reducing the judgment amount on an inmate’s state-law claim of negligent supervision of the tortfeasor-officer by the employer (para 10).

Disposition

• The Supreme Court of the State of New Mexico held that the Corrections Corporation of America and Warden Barbara Wagner are vicariously liable for all compensatory damages caused by the corrections officer's intentional torts. The Court ruled that no affirmative defense of comparative fault is available in this context, thus making the determination of comparative fault in claims of negligent supervision unnecessary (para 12).

Reasons

• The Court, led by Justice Charles W. Daniels, reasoned that under New Mexico law, an employer is vicariously liable for an employee’s torts committed within the scope of employment, especially when the employee was aided in accomplishing the tort by the existence of the agency relation. The Court adopted the aided-in-agency theory, recognizing that corrections officers wield extraordinary power over inmates, which significantly facilitates the commission of such torts. The Court found that the Corrections Corporation of America and Warden Barbara Wagner provided the environment and authority that enabled Townes to commit the assaults, thus making them vicariously liable for the resulting damages. The Court declined to address the applicability of comparative fault to the negligent supervision claim, as the vicarious liability determination rendered it unnecessary (paras 13-22).