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 Petitioner sought to challenge a district court's pretrial order requiring a jury to listen to the entire taped transcript of a Human Rights Commission hearing before additional evidence could be introduced. The case arose from an appeal of a Human Rights Commission order, with the Petitioner seeking a trial de novo in the district court as permitted under NMSA 1978, Section 28-1-13 (paras 1-2).
Procedural History
- Human Rights Commission: Issued an order that was appealed by the Petitioner to the district court (para 1).
- District Court: Issued a pretrial order requiring the jury to review the entire transcript of the Human Rights Commission hearing before hearing additional evidence (para 2).
Parties' Submissions
- Petitioner: Argued that there is no statutory requirement for the jury or judge to review the transcript of the Human Rights Commission hearing before conducting a trial de novo. The Petitioner sought relief from the district court's pretrial order (paras 1-2, 6).
- Respondent: Relied on the precedent set in Keller v. City of Albuquerque, which suggested that the transcript of the commission hearing must be reviewed during a trial de novo (para 2).
Legal Issues
- Does NMSA 1978, Section 28-1-13 require a jury or judge to review the transcript of a Human Rights Commission hearing before conducting a trial de novo?
- What is the proper scope of a trial de novo under NMSA 1978, Section 28-1-13?
Disposition
- The Supreme Court of New Mexico granted the relief requested by the Petitioner and remanded the case to the district court for proceedings consistent with its opinion (para 8).
Reasons
Per Ransom CJ (Montgomery and Franchini JJ. concurring):
The Court held that the statutory language of NMSA 1978, Section 28-1-13 does not require the jury or judge to review the transcript of the Human Rights Commission hearing before conducting a trial de novo. The Court emphasized that a trial de novo is intended to provide a full evidentiary hearing, unconstrained by the record of the prior administrative proceedings (paras 6-8).
The Court overruled the interpretation in Keller v. City of Albuquerque to the extent that it suggested the transcript must be reviewed during a trial de novo. It reasoned that requiring the jury to review the transcript would be duplicative, burdensome, and would undermine the jury's ability to assess witness credibility through live testimony (paras 6-7).
The Court clarified that while the transcript may be used for evidentiary purposes, such as impeachment, it is not mandatory for the district court to review it as part of the trial de novo process. The legislature's intent was to provide a "trial anew," allowing for the presentation of additional relevant evidence beyond the administrative record (paras 6-8).