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 former employee of the Defendant, alleged that her immediate supervisor sexually harassed her during her employment as a housekeeper and laundry aide. She claimed that after rejecting his advances, she was reassigned to a less favorable position and later forced to resign. The Plaintiff reported the harassment to a senior supervisor, who took no remedial action. She subsequently filed complaints with the Equal Employment Opportunity Commission (EEOC) and the New Mexico Human Rights Division (NMHRD), alleging sex discrimination and retaliation. She also filed a workers' compensation claim for physical and emotional injuries resulting from the harassment (paras 2-4).
Procedural History
- District Court of Bernalillo County: The court dismissed the Plaintiff's claim for sex discrimination under the New Mexico Human Rights Act (NMHRA), finding that she failed to exhaust administrative remedies and that her claim was barred by the exclusivity provisions of the Workers' Compensation Act (WCA) (paras 6-7).
Parties' Submissions
- Plaintiff-Appellant: Argued that she had exhausted her administrative remedies by filing her complaint with the EEOC, which acted as an agent for the NMHRD under a work-sharing agreement. She also contended that her NMHRA claim was not barred by the WCA because the injuries addressed under the NMHRA were distinct from those compensated under workers' compensation (paras 7, 13, 21).
- Defendants-Appellees: Asserted that the Plaintiff failed to exhaust administrative remedies by not filing her complaint directly with the NMHRD. They also argued that her NMHRA claim was barred by the WCA's exclusivity provisions and by the release she signed as part of her workers' compensation settlement (paras 6, 15).
Legal Issues
- Did the Plaintiff exhaust her administrative remedies under the NMHRA by filing her complaint with the EEOC?
- Is the Plaintiff's claim for sex discrimination under the NMHRA barred by the exclusivity provisions of the WCA or by her workers' compensation settlement?
Disposition
- The Supreme Court of New Mexico reversed the district court's dismissal and remanded the case for further proceedings (para 23).
Reasons
Per Baca J. (Frost C.J. and Minzner J. concurring):
- The Court held that the Plaintiff exhausted her administrative remedies under the NMHRA by filing her complaint with the EEOC, as the EEOC and NMHRD had a work-sharing agreement that allowed complaints filed with one agency to be deemed filed with the other. The Plaintiff also complied with NMHRD procedures by obtaining an order of nondetermination and appealing to the district court (paras 9-13).
- The Court found that the WCA's exclusivity provisions did not bar the Plaintiff's NMHRA claim because the two statutes address distinct injuries. The WCA compensates for physical and psychological injuries arising from workplace incidents, while the NMHRA addresses broader issues of discrimination and retaliation. The Plaintiff must, however, prove that her damages under the NMHRA are separate from those compensated under the WCA (paras 15-21).
- The Court rejected the Defendants' argument that the Plaintiff's workers' compensation settlement released them from liability under the NMHRA, as the release explicitly excluded her EEOC claim (para 14).