Justia Labor & Employment Law Opinion Summaries

Ana Lilia Cardenas, a special education teacher, injured her knee at work, resulting in both a physical impairment to her knee and a secondary mental impairment. The Workers’ Compensation Judge awarded her permanent partial disability (PPD) benefits for her knee injury, limited to 150 weeks as per the Workers’ Compensation Act. The Act also limits the duration of PPD benefits for secondary mental impairments to the maximum period allowable for the initial physical impairment, which in this case was also 150 weeks.Cardenas appealed, arguing that this limitation violated the equal protection clause of the New Mexico Constitution. The New Mexico Court of Appeals agreed, holding that the Act’s provisions for secondary mental impairments were unconstitutional because they treated workers with mental impairments differently from those with subsequent physical impairments. The Court of Appeals noted that subsequent physical impairments are treated as separate injuries with their own benefit durations, unlike secondary mental impairments.The New Mexico Supreme Court reviewed the case to determine the constitutionality of the Act’s provisions. The Court held that the Act’s differential treatment of secondary mental impairments compared to subsequent physical impairments violated the equal protection clause. The Court applied intermediate scrutiny, given that mental disabilities are a sensitive class, and found that the employer failed to demonstrate that the disparate treatment was substantially related to an important governmental interest. Consequently, the Court affirmed the Court of Appeals' decision, ruling that the relevant sections of the Workers’ Compensation Act were unconstitutional. View "Aztec Municipal Schools v. Cardenas" on Justia Law

Following the death of Patricia Lewis (Worker), her widower Michael Lewis (Petitioner) was awarded death benefits under the Workers’ Compensation Act. The Workers’ Compensation Judge (WCJ) based the award on the finding that Worker, while employed with Albuquerque Public Schools (Employer), contracted allergic bronchopulmonary aspergillosis (ABPA) which proximately resulted in Worker’s death. Employer appealed the award to the Court of Appeals. Pertinent here, the appellate court concluded: (1) the WCJ correctly rejected Employer’s argument that Petitioner’s claim for death benefits was time-barred; and (2) he WCJ erred in excluding from evidence certain medical testimony and records which Employer contended related to Worker’s cause of death. The Court of Appeals therefore remanded the case for retrial on whether Worker’s ABPA “‘proximately result[ed]’” in her death. On the first issue, the New Mexico Supreme Court agreed with the Court of Appeals that Petitioner’s claim for death benefits was not time-barred, and affirmed. On the second issue concerning the WCJ’s exclusion of medical testimony and evidence on Worker’s cause of death, the Supreme Court held the Court of Appeals erred in its interpretation of Section 52-1-51(C), but agreed based on the Supreme Court's own interpretation of Section 52-1-51(C) that the case had to be remanded for further proceedings. In all other respects, the opinion of the Court of Appeals was affirmed. View "Lewis v. Albuquerque Public Schools" on Justia Law

Casey Baker (Worker) appealed a Workers’ Compensation Administration decision denying his request that Endeavor Services, Inc. and Great West Casualty Company (Employer) pay 100% of Worker’s attorney fees pursuant to the fee-shifting provision set forth in NMSA 1978, Section 52-1-54(F)(4) (2003, amended 2013). At issue was whether Worker made an offer of judgment that was sufficient to trigger the fee-shifting provision. The New Mexico Supreme Court found Worker’s offer of judgment put Employer on notice that Worker was proposing an unambiguous partial settlement and that Worker intended to invoke the fee-shifting statute. Therefore, Worker made a valid offer under Section 52-1-54(F) (2003) and the workers’ compensation judge erred as a matter of law by declining to apply the mandatory fee-shifting provision. The case was remanded for further proceedings. View "Baker v. Endeavor Servs." on Justia Law

Plaintiff Natalie Garcia (née Watkins), sued her former employer, Defendant Hatch Valley Public Schools (HVPS), for employment discrimination under the New Mexico Human Rights Act (NMHRA). Plaintiff alleged that HVPS terminated her employment as a school bus driver based on her national origin, which she described as “German” and “NOT Hispanic.” HVPS successfully moved for summary judgment in the district court, and the Court of Appeals reversed, focusing on Plaintiff’s “primary contention” that HVPS had discriminated against her and terminated her employment because she was not Hispanic. The New Mexico Supreme Court reversed the Court of Appeals, holding that summary judgment in HVPS' favor was appropriate because Plaintiff failed to establish a prima facie case of discrimination and failed to raise a genuine issue of material fact about whether HVPS’ asserted reason for terminating her employment was pretextual. In so holding, the Court also concluded: (1) the Court of Appeals properly focused on Plaintiff’s contention that she was not Hispanic in analyzing her discrimination claim; (2) Plaintiff could claim discrimination under the NMHRA as a non-Hispanic; and (3) the plain language of the NMHRA did not place a heightened evidentiary burden on a plaintiff in a "reverse" discrimination case. View "Garcia v. Hatch Valley Pub. Schs." on Justia Law

Plaintiff Natalie Garcia (née Watkins), sued her former employer, Defendant Hatch Valley Public Schools (HVPS), for employment discrimination under the New Mexico Human Rights Act (NMHRA). Plaintiff alleged that HVPS terminated her employment as a school bus driver based on her national origin, which she described as “German” and “NOT Hispanic.” HVPS successfully moved for summary judgment in the district court, and the Court of Appeals reversed, focusing on Plaintiff’s “primary contention” that HVPS had discriminated against her and terminated her employment because she was not Hispanic. The New Mexico Supreme Court reversed the Court of Appeals, holding that summary judgment in HVPS' favor was appropriate because Plaintiff failed to establish a prima facie case of discrimination and failed to raise a genuine issue of material fact about whether HVPS’ asserted reason for terminating her employment was pretextual. In so holding, the Court also concluded: (1) the Court of Appeals properly focused on Plaintiff’s contention that she was not Hispanic in analyzing her discrimination claim; (2) Plaintiff could claim discrimination under the NMHRA as a non-Hispanic; and (3) the plain language of the NMHRA did not place a heightened evidentiary burden on a plaintiff in a "reverse" discrimination case. View "Garcia v. Hatch Valley Pub. Schs." on Justia Law

Plaintiff and the corporate Defendants freely negotiated and entered into a clear and unambiguous contract for Plaintiff to sell their insurance policies. In the contract, Plaintiff consented to a provision allowing Defendants to immediately terminate the contract if he breached it in any one of five different specified ways. Plaintiff breached the contract, and Defendants exercised their right to terminate. Plaintiff sued Defendants under numerous theories of liability for terminating the contract, including under the doctrine of prima facie tort, asserting that Defendants had nefarious reasons for terminating the contract. After review, the New Mexico Supreme Court held that when a contract is clear, unambiguous, and freely entered into, the public policy favoring freedom of contract precludes a cause of action for prima facie tort when the gravamen of the allegedly tortious action was the defendant’s exercise of a contractual right. View "Beaudry v. Farmers Ins. Exch." on Justia Law

The United States District Court for the District of New Mexico certified a question of New Mexico law to the state Supreme Court. The question centered on whether a worker injured in the course of employment by a co-worker operating an employer owned motor vehicle was a person “legally entitled to recover damages” under his employer’s uninsured/underinsured motorist coverage. Andrew Vasquez was killed at the workplace after being struck by a steel beam that fell off of a forklift during the course of his employment at Coronado Wrecking and Salvage. A coworker operating the forklift had jumped off to check whether the steel beam being lifted was secure, leaving the forklift unattended as the steel beam slid off of the forks, striking and killing Vasquez. Plaintiff, Vasquez’s estate, subsequently collected workers’ compensation benefits from Coronado’s workers’ compensation carrier. Related to the forklift accident, Plaintiff also collected uninsured motorist benefits under Vasquez’s own automobile insurance policy.The certified question from the district court arose from an alleged discontinuity among the plain language of New Mexico’s Workers’ Compensation Act (WCA), the Uninsured Motorist statute, and the New Mexico Court’s case law. Because the WCA provided the exclusive remedy for an employee injured in a workplace accident by an employer or its representative, the employee was not legally entitled to recover damages from the uninsured employer tortfeasor under the Uninsured Motorist statute. The Court therefore answered the certified question in the negative. View "Vasquez v. American Cas. Co. of Reading" on Justia Law

These consolidated appeals presented an issue to the New Mexico Supreme Court on whether farm and ranch laborers' exclusion from coverage under the state Workers' Compensation Act violated the rights of those workers under the Equal Protection Clause of Article II, Section 18 of the New Mexico Constitution in light of the fact that other agricultural workers are not singled out for exclusion. After review of these cases, the Supreme Court concluded that there was nothing to distinguish farm and ranch laborers from other agricultural employees and that purported government interests such as cost savings, administrative convenience, and other justifications related to unique features of agribusiness bore no rational relationship to the Act’s distinction between these groups. "This is nothing more than arbitrary discrimination and, as such, it is forbidden by our Constitution." Accordingly, the Court held that the farm and ranch laborer exclusion contained in Section 52-1-6(A) of the Act was unconstitutional, and these cases were remanded for further proceedings. View "Rodriguez v. Brand West Dairy" on Justia Law

Petitioners, American Federation of State, County and Municipal Employees, Council 18, AFL-CIO, Locals 1461, 2260 and 2499 (AFSCME), brought a declaratory-judgment action challenging the grandfather status of Respondent’s Board of County Commissioners of Bernalillo County (County Commission), local labor relations board. Both the trial and appellate courts rejected AFSCME’s claims. In its review, the New Mexico Supreme Court focused on the statutory jurisdictional prerequisites of New Mexico’s Declaratory Judgment Act, NMSA 1978, §§ 44-6-1 to -15 (1975), and held that AFSCME’s claims were not ripe, and AFSCME failed to assert an injury-in-fact. Accordingly, the district court lacked jurisdiction to adjudicate AFSCME’s declaratory-judgment action. The case was remanded to the district court to dismiss for lack of jurisdiction. The Court of Appeals also lacked jurisdiction, and its opinion was vacated. View "AFSCME v. Bd. of Cty. Comm'rs of Bernalillo Cty." on Justia Law

Phillip Ramirez, a member of the New Mexico Army National Guard, was employed by the New Mexico Children, Youth and Families Department (CYFD). In July 2005, Ramirez was ordered to federal active duty and deployed to Iraq. After Ramirez returned to work in New Mexico, CYFD terminated his employment. Ramirez sued CYFD, asserting a Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) claim. A jury found in his favor and awarded Ramirez monetary damages. The Court of Appeals reversed the damages award, concluding that CYFD as an arm of the State was immune to Ramirez’s USERRA claim. After review of that decision, the New Mexico Supreme Court disagreed: by enacting NMSA 1978, Section 20-4-7.1(B) (2004), the Legislature specifically extended “[t]he rights, benefits and protections” of USERRA to members of the New Mexico National Guard who were ordered to federal or state active duty for a period of thirty or more consecutive days. In so doing, the Legislature consented to suits brought against state employers who violate the protections guaranteed by USERRA. View "Ramirez v. CYFD" on Justia Law