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, a female employee of a New Mexico corporation, alleged wage discrimination under the New Mexico Human Rights Act (NMHRA) and breach of contract. She claimed she was paid less than male managers of subsidiary offices and that the Defendants failed to repurchase her stock as promised upon her departure. The Defendants argued that the wage comparison was invalid due to the corporate structure and denied the existence of an unconditional stock repurchase agreement (paras 1, 3-8).
Procedural History
- District Court of Bernalillo County: The jury found in favor of the Plaintiff, awarding $206,416 for wage discrimination and $63,607 for breach of contract. The court also awarded prejudgment interest and attorney’s fees (para 1).
Parties' Submissions
- Defendants-Appellants: Argued that the trial court erred in allowing the corporate president to be sued personally, permitting wage comparisons with subsidiary managers, and rejecting their jury instructions. They also contended that the evidence did not support the discrimination claim or the damages awarded. Regarding the breach of contract, they argued improper jury instructions, insufficient evidence, and excessive damages (para 1).
- Plaintiff-Appellee: Asserted that she was discriminated against based on her gender, earning less than male managers despite similar or greater responsibilities. She also claimed the Defendants breached their agreement to repurchase her stock upon her departure (paras 1, 3-8).
Legal Issues
- Whether the corporate president could be held personally liable under the NMHRA.
- Whether the Plaintiff could compare her wages to those of managers in subsidiary offices to establish wage discrimination.
- Whether the jury instructions on discrimination and breach of contract were proper.
- Whether the evidence supported the discrimination and breach of contract claims.
- Whether the damages awarded for discrimination and breach of contract were excessive.
Disposition
- The corporate president was not personally liable under the NMHRA due to the Plaintiff’s failure to exhaust administrative remedies against him (para 2).
- The trial court’s judgment on the discrimination claim was affirmed, including the damages awarded (para 2).
- The breach of contract claim was affirmed, but the damages were remanded for recalculation based on the corporation’s book value at the time of the breach (para 2).
Reasons
Per Franchini J. (Minzner, Maes, Serna, and Baca JJ. concurring in result):
Individual Liability: The NMHRA allows for individual liability, but the Plaintiff failed to exhaust administrative remedies against the corporate president, precluding personal liability (paras 12-13).
Wage Comparisons: The Plaintiff could compare her wages to those of subsidiary managers because the parent corporation controlled their salaries. The NMHRA does not impose a "single establishment" requirement like the federal Equal Pay Act (paras 14, 23-26).
Jury Instructions: The trial court’s instructions on discrimination and breach of contract were adequate. The Defendants failed to preserve objections to some instructions and did not demonstrate prejudice from any alleged errors (paras 15-19, 34-36).
Sufficiency of Evidence: The Plaintiff provided sufficient evidence of wage discrimination, including testimony about her responsibilities and salary disparities. The jury could reasonably infer intentional discrimination. The breach of contract claim was also supported by evidence of an agreement to repurchase stock (paras 22-31, 37).
Damages: The discrimination damages were within the range supported by the evidence. However, the breach of contract damages were excessive because they were calculated based on the corporation’s value three years after the breach. The proper measure is the value at the time of the breach (paras 32, 38).
Per Serna CJ. (Baca J. concurring in result):
- Agreed with the result but expressed concerns about the majority’s analysis of individual liability and the parent-subsidiary relationship. Emphasized that liability under the NMHRA should not disregard corporate structures and suggested adopting federal tests to determine whether a parent and subsidiary should be treated as a single entity. Also criticized the jury instructions for failing to adequately address the Plaintiff’s burden to prove pretext and the comparability of employees (paras 41-50).