This case concerns the accrual of a legal malpractice claim and the running of New Mexico's four-year statute of limitations under NMSA 1978 Sections 37-1-1 and -4. Sharts sued his former attorney Natelson for negligently preparing restrictive covenants in 1978 that later prevented Sharts from developing the southern half of his land into smaller lots, leading to financing problems and a 1984 declaratory judgment action against neighboring owners that Sharts lost. The trial court denied the defendants' motion for summary judgment, finding a genuine issue of material fact on when actual harm first existed, but the Supreme Court reversed and ordered summary judgment for the defendants. The court held that the claim accrued by 1983 at latest, when Sharts received enforcement threats and learned the covenants clouded his title, and that even the continuous-representation doctrine would have ended tolling by June 1985 when new counsel appeared, making the suit untimely.
In Brooks v. Shanks, an inmate petitioned for a writ of habeas corpus alleging that his eligibility for meritorious good-time credits was terminated without following statutory procedures under NMSA 1978, Sections 33-2-34 and 33-2-36, which require a classification committee recommendation and warden approval. The district court dismissed the petition without an evidentiary hearing, relying on prior precedent suggesting no judicial review for such deprivations. The New Mexico Supreme Court reversed, holding that the statutes create an entitlement to good-time credits that may be divested only through the specified administrative processes, and that the petitioner's allegations, combined with the warden's response, were sufficient to mandate an evidentiary hearing under SCRA 5-802(E)(3); the court also limited language in State v. Aqui that had been interpreted to bar such review. The matter was remanded for further proceedings.
In State v. Vallejos, the defendant was convicted of first-degree felony murder and armed robbery after being compelled under an immunity order to testify at a co-defendant's preliminary hearing. She appealed on the ground that the prosecution's derivative use of her immunized testimony, including through the co-defendant's later trial testimony, violated her Fifth Amendment privilege against self-incrimination. The New Mexico Supreme Court reversed the convictions, holding that the state failed to meet its heavy burden under Kastigar and Munoz to prove that none of its evidence was tainted by the immunized testimony despite the use of a "Chinese Wall" and separate prosecutors. The court emphasized that the constitutional protection must prevail over prosecutorial convenience and remanded for retrial or further proceedings consistent with its guidelines on use immunity.
This case concerned whether a New Mexico state district court had subject-matter jurisdiction to adjudicate a dispute between the Jicarilla Apache Tribe and Rio Arriba County over the existence of a public prescriptive easement across a ranch the Tribe had recently purchased, which was later added to its reservation. After a bench trial, the district court ruled in the County's favor on the easement issue, but the Court of Appeals reversed, finding jurisdiction lacking under federal law. The New Mexico Supreme Court reversed the Court of Appeals, holding that 28 U.S.C. § 1360(b) (part of Public Law 280) did not preempt state-court jurisdiction. The core reasoning was that the dispute involved state-law property principles to determine what interest the Tribe acquired when purchasing land from private owners outside the reservation, rather than regulating or taxing Indian lands or property in a manner barred by the federal statute.
The case concerned a school board's discharge of its superintendent for alleged good cause and the employee's challenge to the constitutionality of a statute mandating compulsory arbitration of such disputes along with severely limited judicial review. The arbitrator upheld the discharge after an extensive hearing, and the district court confirmed the award. The New Mexico Supreme Court held that compulsory arbitration of certified school-employee discharge disputes is constitutional and does not violate due process, jury-trial rights, court access, or separation of powers. However, the statutory restriction of judicial review to only corruption, fraud, deception, or collusion was unconstitutional because due process and the judicial power require de novo review of legal questions and substantial-evidence review of factual findings. The court therefore reversed the confirmation order and remanded for further proceedings applying the proper standard of review.
This case concerned whether New Mexico's recognition of a prima facie tort cause of action in Schmitz v. Smentowski should apply retroactively to pre-Schmitz conduct in an employment dispute where a secretary alleged intentional humiliation by her supervisor leading to a $76,000 jury verdict. The Court of Appeals had held the new tort rule applied only prospectively, but the Supreme Court reversed that determination. The court declined to adopt the U.S. Supreme Court's Harper rule requiring full retroactivity for new civil rules in all pending cases, choosing instead to retain the flexible Chevron Oil multi-factor test previously followed in New Mexico. Applying that test, the court concluded the Court of Appeals had misapplied the factors and that the prima facie tort rule must be given retroactive effect to the parties' earlier conduct.