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, an appraiser for Lincoln County since 1984, was terminated in 1989 by the County Assessor after running against her in an election. The termination was allegedly based on violations of the County personnel handbook, but the Plaintiff argued that the termination was in bad faith and without cause. The handbook required progressive discipline for job-related infractions unless the misconduct was of a serious nature akin to illegal activity (paras 2-3, 8, and 17-18).
Procedural History
- Lincoln County Grievance Board: Upheld the termination decision based on evidence presented by the County Assessor (paras 4 and 8).
- District Court: Treated the case as an appeal from an administrative decision, upheld the termination, and found that procedural due process was followed. However, it also found that the termination was in bad faith but declined to award damages (paras 9-10, 19).
Parties' Submissions
- Plaintiff-Appellant: Argued that the termination was in bad faith, violated the employment contract, and failed to follow the progressive discipline procedures outlined in the personnel handbook. The Plaintiff also contended that the trial court erred in not granting a trial de novo (paras 2, 11, and 19).
- Defendants-Appellees: Asserted that the termination was justified based on the Plaintiff's alleged misconduct and that procedural due process was provided through the grievance process (paras 8-10).
Legal Issues
- Was the Plaintiff entitled to a trial de novo in district court to determine the validity of the termination?
- Did the County Assessor breach the Plaintiff's employment contract by terminating him in bad faith and failing to follow the progressive discipline procedures?
- Was the Plaintiff entitled to damages for wrongful termination?
Disposition
- The Supreme Court of New Mexico reversed the district court's judgment and remanded the case for entry of judgment in favor of the Plaintiff and for a determination of damages (para 20).
Reasons
Per Franchini J. (Baca C.J. and Frost J. concurring):
The Court held that the district court erred in treating the case as an appeal from an administrative decision rather than conducting a trial de novo. The Plaintiff was entitled to a full trial on the merits to determine whether the termination was valid, as the grievance board was not an independent quasi-judicial body (paras 16 and 18).
The Court found that the County Assessor acted in bad faith by terminating the Plaintiff for running against her in the election. The alleged misconduct did not rise to the level of serious misconduct or illegal activity that would justify immediate termination under the personnel handbook. Progressive discipline should have been applied, and the termination was therefore invalid (paras 10, 17-18).
The Court concluded that the Plaintiff was entitled to damages for breach of the employment contract, as the termination violated his substantive rights. The district court's refusal to award damages was incorrect, as it effectively allowed the County to terminate employees arbitrarily as long as procedural due process was followed (para 19).