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's son committed suicide while incarcerated at the Santa Fe Detention Center, which was operated by the defendant, a private corrections corporation. The plaintiff alleged that the defendant's employees violated the decedent's constitutional rights and that the defendant negligently failed to train and supervise its employees in the proper care of prisoners (paras 2-3).
Procedural History
- District Court of Santa Fe County: Denied the defendants' motion for partial summary judgment on the plaintiff's second cause of action, which alleged negligent training and supervision (para 3).
Parties' Submissions
- Defendants-Appellants: Argued that the plaintiff had no cause of action for negligent training or supervision due to the immunity granted under the New Mexico Tort Claims Act (para 3).
- Plaintiff-Appellee: Contended that the immunity was waived under Section 41-4-12 of the Tort Claims Act because the negligent training and supervision caused a deprivation of the decedent's constitutional rights, resulting in personal injury and death (paras 3-4).
Legal Issues
- Does the New Mexico Tort Claims Act waive immunity for negligent training and supervision by law enforcement officers when such negligence causes a deprivation of constitutional rights or a specified tort?
- Can the plaintiff's second cause of action for negligent training and supervision proceed under the Tort Claims Act?
Disposition
- The Court of Appeals affirmed the district court's denial of the defendants' motion to dismiss the second cause of action and remanded the case for further proceedings (para 8).
Reasons
Per Hartz J. (Minzner J. concurring):
The court held that the New Mexico Tort Claims Act waives immunity for negligent training and supervision by law enforcement officers only when such negligence proximately causes a specified tort listed in Section 41-4-12 or a deprivation of constitutional or statutory rights (paras 1, 6). The court rejected the district court's broader interpretation of the Act, which suggested that immunity is waived for negligent training and supervision alone (para 5). However, the court found that the plaintiff's complaint could reasonably be construed as alleging that the defendants' negligence caused a deprivation of the decedent's constitutional rights, which resulted in personal injury and death. Therefore, the second cause of action was sufficient to survive the motion to dismiss, subject to further factual or legal challenges (paras 7-8).
Per Bivins J., dissenting:
Bivins J. dissented, adopting his dissenting opinion in the related case of Ortiz v. New Mexico State Police, 112 N.M. 249, 814 P.2d 117 (Ct. App. 1991) (para 10).