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 chief resident in the neurosurgery division at the University of New Mexico School of Medicine, was accused of alcohol addiction by a colleague. Following this, his supervisor required him to attend substance-abuse counseling and sign a voluntary agreement to participate in the New Mexico Monitored Treatment Program (MTP). The plaintiff's compliance with the program declined, and he objected to its religious content. His employment was terminated after continued non-compliance and concerns about his behavior and performance (paras 1-17).
Procedural History
- District Court of Bernalillo County: The trial court dismissed the plaintiff's first three causes of action for failure to state a claim, finding that the defendants were not state actors. The fourth cause of action was dismissed on summary judgment, as the court found the plaintiff had consented to the disclosure of information (paras 2-3).
Parties' Submissions
- Plaintiff-Appellant: Argued that the defendants acted as state actors by participating with state employees in depriving him of constitutional rights and by accepting state-delegated authority over his employment. He also claimed that he revoked his consent to the disclosure of information before it was shared with his employer (paras 3, 18, 25).
- Defendants-Appellees: Contended that they were not state actors and could not be held liable for civil rights violations. They also argued that the plaintiff's consent to the disclosure of information justified their actions and that there was no improper interference with the plaintiff's employment contract (paras 18, 26).
Legal Issues
- Were the defendants state actors for the purposes of the plaintiff's civil rights claims?
- Did the defendants improperly interfere with the plaintiff's contractual relationship with his employer?
Disposition
- The Court of Appeals affirmed the trial court's dismissal of the plaintiff's claims (para 37).
Reasons
Per Pickard CJ (Bosson and Armijo JJ. concurring):
State Action: The court held that the defendants were not state actors. While the hospital conditioned the plaintiff's employment on compliance with the MTP, the program and its administrator did not have the authority to hire or fire the plaintiff. Their actions did not constitute state action under the "public function" doctrine or joint participation with the state (paras 20-24).
Interference with Contractual Relations: The court found that the defendants' actions were justified under the terms of the plaintiff's agreements. The MTP had a contractual obligation to notify the hospital of the plaintiff's non-compliance, and the plaintiff's employment contract implied that his participation in the program was mandatory. The defendants' communications with the hospital were therefore privileged and not improper (paras 29-36).