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, formerly employed as the Equal Employment Opportunity (EEO) and Americans with Disabilities Act (ADA) coordinator for the City of Las Cruces, was terminated from his position. He claims that his termination was due to age and/or sex discrimination, as well as retaliation for processing an ADA discrimination complaint against his supervisor (paras 1, 7).
Procedural History
- District Court: Granted summary judgment in favor of the City of Las Cruces, dismissing the Plaintiff's claims of discrimination and retaliation (para 1).
Parties' Submissions
- Plaintiff-Appellant: Argued that he presented sufficient evidence to support claims of age and/or sex discrimination and retaliation under the New Mexico Human Rights Act (NMHRA) (para 1).
- Defendant-Appellee: Asserted that the Plaintiff's termination was based on a legitimate business reason, specifically his conduct during a new employee orientation training, which resulted in formal complaints and policy violations (para 4).
Legal Issues
- Whether the Plaintiff established a prima facie case of age and/or sex discrimination.
- Whether the Plaintiff established a prima facie case of retaliation under the NMHRA.
- Whether the City of Las Cruces provided a legitimate business reason for the Plaintiff's termination.
- Whether the Plaintiff provided sufficient evidence to demonstrate that the City's reason for termination was pretextual.
Disposition
- The Court of Appeals reversed the summary judgment on the Plaintiff's age and/or sex discrimination claims.
- The Court of Appeals affirmed the dismissal of the Plaintiff's retaliation claim (para 1).
Reasons
Per Wray J. (Attrep C.J. and Bogardus J. concurring):
The Court found that the Plaintiff established a prima facie case of age and/or sex discrimination, as he provided evidence of positive performance reviews and that his replacement was younger and female. The City provided a legitimate business reason for termination, citing the Plaintiff's conduct during a training session. However, the Plaintiff raised a genuine issue of material fact regarding pretext by showing that a prior female coordinator with similar conduct was not disciplined (paras 3-6).
Regarding the retaliation claim, the Court concluded that the Plaintiff did not engage in a protected activity under the NMHRA, as his actions did not constitute opposition to an unlawful practice or participation in a proceeding under the NMHRA. Therefore, the Plaintiff failed to establish a prima facie case for retaliation (paras 7-9).