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

A tenured professor at the University of New Mexico (UNM) School of Medicine, who also held administrative roles, was removed from his position as director of a developmental disabilities program. He alleged that this removal violated his employment contract, the faculty handbook, and internal policies. The professor claimed that his removal was without just cause and breached both express and implied terms of his contract (paras 1-6).

Procedural History

• District Court: Denied UNM's motion for summary judgment, finding that genuine issues of material fact existed regarding the breach of contract claim and rejecting UNM's assertion of sovereign immunity (paras 6, 18).
• Court of Appeals: Certified the case to the Supreme Court of New Mexico, citing the matter as one of substantial public importance (para 6).

Parties' Submissions

• Plaintiff (Professor): Argued that his removal violated his written employment contract, the faculty handbook, and internal policies. He claimed that the removal was without just cause and breached an implied covenant of good faith and fair dealing (paras 6, 19).
• Defendants (UNM and Officials): Asserted sovereign immunity under NMSA 1978, § 37-1-23, arguing that the claim was based on an unwritten contract. They also contended that the professor's administrative roles were at-will positions and not protected by tenure (paras 6, 19-20).

Legal Issues

• Does sovereign immunity under NMSA 1978, § 37-1-23(A) apply to the professor's breach of contract claim?
• Did the trial court err in determining that genuine issues of material fact existed regarding the breach of contract claim?

Disposition

• The Supreme Court of New Mexico affirmed the trial court's denial of sovereign immunity, finding that the claim was based on a written contract (para 17).
• The Court dismissed the appeal regarding the trial court's determination of genuine issues of material fact, holding that it was not subject to review under the collateral order doctrine (para 21).

Reasons

Per Serna J. (Minzner C.J., Baca, Franchini, and Maes JJ. concurring):

The Court held that sovereign immunity under NMSA 1978, § 37-1-23(A) does not apply to actions based on valid written contracts. The professor's claim was based on his written employment contracts, which included administrative duties, and thus was not barred by sovereign immunity. The Court emphasized that the immunity statute applies only to unwritten contracts (paras 17-18).

The Court also clarified that the collateral order doctrine allows interlocutory appeals only for issues entirely separate from the merits of the case. While the immunity question was reviewable, the trial court's determination that genuine issues of material fact existed regarding the breach of contract claim was intertwined with the merits and not subject to immediate appeal. The Court noted that such issues are better resolved at trial and reviewed on appeal from a final judgment (paras 15-21).

Per Franchini J., dissenting in part (Maes J. concurring):

Justice Franchini dissented, arguing that the professor's administrative position as director of the program was not included in his 1994-1995 written contract. He contended that the professor's claim was based on an implied contract, which is barred by sovereign immunity under NMSA 1978, § 37-1-23(A). Franchini would have granted summary judgment in favor of UNM (paras 24-32).