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Sanders v. N.M. Corr. Dep't
New Mexico Supreme Court · 2024-10-10 · cited 8×
This case involved a wrongful death suit by the estate of Katherine Paquin against the New Mexico Corrections Department and officials, alleging that the Department negligently released inmate Christopher Blattner three years early due to record-keeping errors, after which Blattner murdered Paquin off-premises. The district court granted summary judgment to the Department, finding the Tort Claims Act's building waiver under NMSA 1978, § 41-4-6(A) inapplicable to off-premises injuries or administrative functions. The Court of Appeals reversed, and the New Mexico Supreme Court affirmed, holding that the building waiver contains no geographical limitation and that negligent prisoner release, if sufficiently pleaded, can constitute negligent operation of a public facility. The Court disavowed prior precedent categorically excluding administrative functions from the waiver while preserving the requirement that the danger affect the general public or a class of persons rather than a single individual.
criminal lawtorts & liability
State ex rel. Franchini v. Toulouse Oliver
New Mexico Supreme Court · 2022-06-02
This case concerned the constitutionality of New Mexico legislation (Senate Bill 266) that staggered the retention election cycles for district and metropolitan court judges. Petitioners, sitting judges and their association, sought a writ of mandamus arguing that Article VI, Section 33 of the state constitution required all such judges to stand for retention at the same time and that this more specific provision controlled over a 2020 amendment to Article XX, Section 3. The Supreme Court denied the petition, holding that the voters' approval of the Article XX amendment expressly authorized the Legislature to stagger elections for particular state, county, or district offices, thereby permitting the staggered judicial retention schedules in Sections 1-26-5 and -6. The Court reasoned that the amendment implicitly repealed any contrary uniformity requirement in Article VI and that the legislation was therefore constitutional.
elections
Sais v. NEW MEXICO DEPT. OF CORRECTIONS
New Mexico Supreme Court · 2012-03-22 · cited 6×
The case involved Rudy Sais, a correctional officer employed by the New Mexico Department of Corrections, who was terminated after his second arrest for driving while intoxicated under the department's DWI Policy, which required self-reporting of arrests and imposed minimum sanctions including dismissal for a second offense. Sais appealed to the State Personnel Board, arguing that the department had treated him differently from at least three other employees with multiple DWI arrests who remained employed. The administrative law judge and district court sided with Sais on grounds of arbitrary and capricious action, but the New Mexico Supreme Court reversed, upholding the Personnel Board's decision to affirm the termination. The court reasoned that, unlike in its prior Kibbe decision, the department had introduced substantial evidence in the record to explain the differing treatment of the other employees, including that some arrests predated the policy, lacked documentation, or did not involve self-reporting that would trigger investigation.
labor & employmentcriminal law
State v. Rivera
New Mexico Supreme Court · 2012-01-05 · cited 16×
The case concerned a DWI conviction obtained in Bernalillo County Metropolitan Court, where an unlicensed individual participated in the prosecution alongside a licensed assistant district attorney. The defendant sought a new trial, arguing that the unauthorized practice of law required reversal. The district court and Court of Appeals affirmed the conviction, relying on a statute that appeared to permit non-attorneys to practice in magistrate courts, of which metropolitan court is a type. The New Mexico Supreme Court affirmed the conviction, reasoning that judicial authority to regulate the practice of law is exclusive and that the licensed prosecutor conducted the case without prejudice from the unauthorized participation.
criminal lawprocedure
State v. Trujillo
New Mexico Supreme Court · 2011-10-27 · cited 23×
In State v. Trujillo, the New Mexico Supreme Court reviewed a district court's suppression of evidence obtained via a search warrant in a criminal case involving allegations that the defendant molested his teenage niece and cousin, including descriptions of sexual acts, pornographic materials, and letters. The Court of Appeals had upheld the suppression on grounds that the supporting affidavit failed to establish a sufficient nexus between the alleged crimes and the specific residence to be searched. The Supreme Court reversed, holding that reviewing courts must defer to the issuing judge's probable cause determination if the affidavit provides a substantial basis for it, and remanded for further proceedings. The core reasoning centered on avoiding substitution of the reviewing court's judgment for that of the warrant-issuing judge when reasonable inferences support the warrant.
criminal lawprocedure
State v. Cruz
New Mexico Supreme Court · 2011-09-14 · cited 7×
In State v. Cruz, the defendant, owner of a construction company, was convicted under New Mexico's Worthless Check Act for issuing four payroll checks that were returned for insufficient funds after workers cashed them at a trading post. The Court of Appeals reversed the convictions, concluding that the Act requires a contemporaneous exchange of value and does not cover checks issued for pre-existing or antecedent debts, such as wages from a prior pay period. The New Mexico Supreme Court reversed that decision, holding that the Act's prohibition on issuing worthless checks "in exchange for anything of value" applies to payroll checks delivered after a typical processing delay. The Court based its ruling on the plain language of the modern statute, its legislative history and purpose, and the rejection of older case law interpretations that imposed a contemporaneous transaction requirement.
criminal lawbusiness & regulatoryproperty