AI Generated Opinion Summaries

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 permanent employee of the Defendant municipality, was injured in a non-work-related accident and was granted six months of unpaid disability leave. After receiving a partial medical release, the Plaintiff requested light-duty work, which was denied by the Mayor until a full medical release was obtained. Upon the expiration of the six-month leave, the Plaintiff was terminated. The Plaintiff appealed the termination to the Village Personnel Board, which upheld the Mayor's decision (paras 2-4).

Procedural History

• Village Personnel Board, October 20, 1990: Upheld the Mayor's decision to terminate the Plaintiff's employment (para 3).
• District Court, March 11, 1994: Granted the Defendant's motion to dismiss, concluding that the Plaintiff failed to perfect a timely appeal and that the proper procedure to appeal the Board's decision was by petitioning for a writ of certiorari (paras 4-5).

Parties' Submissions

• Appellant (Plaintiff): Argued that the Village Personnel Board lacked jurisdiction to hear his breach of implied employment contract claim and that the district court should review the case de novo. He also contended that the Village violated the employment ordinance by failing to assign him to light-duty work (paras 5, 7, 12).
• Appellee (Defendant): Asserted that the Plaintiff could only appeal the Board's decision by filing a writ of certiorari within thirty days and that the Plaintiff's complaint, filed twenty-eight months later, was untimely. The Defendant also argued that no light-duty work was available (paras 4, 5, 12).

Legal Issues

• Was the proper procedure to appeal the Village Personnel Board's decision to petition the district court for a writ of certiorari?
• Was the Plaintiff entitled to a trial de novo in the district court?
• Did the Plaintiff perfect a timely appeal of the Board's decision?

Disposition

• The Supreme Court of New Mexico affirmed the district court's ruling that the proper procedure to appeal the Board's decision was by writ of certiorari.
• The Court reversed the district court's dismissal of the case and remanded it to determine whether the Plaintiff perfected a timely appeal based on the principles of laches (paras 33-34).

Reasons

Per Baca CJ (Ransom, Franchini, Frost, and Minzner JJ. concurring):

• The Court held that municipal personnel boards act in a quasi-judicial capacity when determining employment matters, and absent a statutory provision, their decisions are reviewable by writ of certiorari. The district court's review is limited to determining whether the Board's decision was arbitrary, capricious, fraudulent, or unsupported by substantial evidence (paras 5-6, 13-14, 18).
• The Court rejected the Plaintiff's argument for de novo review, emphasizing that such review is only available when explicitly provided by statute. The Plaintiff failed to identify any statutory provision granting de novo review in this case (paras 13, 16-17, 20-21).
• On the issue of timeliness, the Court clarified that the time limit for filing a writ of certiorari is generally thirty days, but this may be extended based on the principles of laches. The district court erred by dismissing the case without considering whether the Plaintiff had "exceptionally good cause" for the delay or whether the Defendant was prejudiced by it. The case was remanded for this determination (paras 28-32).
• The Court overruled its prior decision in Wheatley v. County of Lincoln, to the extent it conflicted with the principles established in this case, reaffirming that municipal personnel board decisions are subject to limited judicial review (paras 25-26).