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 case concerns a psychologist who retired from practice due to personal and health reasons but later sought to reinstate her license. The New Mexico State Board of Psychologist Examiners required her to pass an oral examination as a condition for reinstatement, citing concerns about her health. The psychologist challenged this requirement, arguing it violated her substantive and procedural due process rights (paras 1-6).
Procedural History
- District Court, Santa Fe County: The court quashed the psychologist's Writ of Certiorari, finding it lacked jurisdiction to review the Board's decision and concluding that due process did not apply to the Board's discretionary actions (paras 7-8).
Parties' Submissions
- Appellant (Psychologist): Argued that the Board's imposition of an oral examination violated her substantive and procedural due process rights. She contended that the requirement was arbitrary and unrelated to her health, and that she was denied a hearing to challenge the decision (paras 1, 6-7, 13).
- Appellee (New Mexico State Board of Psychologist Examiners): Asserted that the oral examination requirement was within its discretion under Rule 12 and necessary to ensure the psychologist's qualifications. The Board argued that the Uniform Licensing Act did not mandate a hearing in this context (paras 4-5, 9-10).
Legal Issues
- Did the district court have jurisdiction to review the Board's decision to require an oral examination for license reinstatement?
- Was the psychologist entitled to substantive and procedural due process in the Board's decision-making process?
Disposition
- The Supreme Court of New Mexico reversed the district court's decision and remanded the case to the Board for reinstatement proceedings that comply with due process (paras 8, 21-22).
Reasons
Per Baca J. (Franchini C.J. and Serna J. concurring):
Jurisdiction: The district court erred in finding it lacked jurisdiction. The court had authority to issue a Writ of Certiorari to review the Board's actions, as the psychologist had no statutory avenue for appeal under the Uniform Licensing Act. The Board's decision to impose the oral examination was final and ripe for review, as it had immediate and significant consequences for the psychologist (paras 9-12).
Substantive Due Process: While the Board's authority to impose an oral examination under Rule 12 was facially valid and rationally related to public health and safety, its application to the psychologist raised concerns. The Board cited her health as the sole reason for the examination, but no evidence was presented to show that the oral examination was relevant to assessing her health. The case was remanded for a hearing to determine whether the requirement was rationally related to a legitimate governmental purpose (paras 13-18).
Procedural Due Process: The psychologist's license to practice was a protected property interest under the Fourteenth Amendment. The Board's failure to provide notice or a hearing before imposing the oral examination violated her procedural due process rights. The Court emphasized that procedural safeguards, such as a hearing, were necessary to prevent arbitrary deprivation of her license. On remand, the Board must provide a hearing to justify the oral examination requirement (paras 19-20).