NM SUPREME COURT News:
SANTA FE — Governmental organizations are immune from liability in civil rights lawsuits for their administrative actions that are judicial in nature, the state Supreme Court ruled today.
The Court unanimously concluded that “the doctrine of judicial immunity extends to claims for damages asserted against a governmental entity, including a public body sued under” the New Mexico Civil Rights Act (CRA).
The justices for the first time interpreted provisions of the civil rights law, which was enacted in 2021 to provide a basis in New Mexico law to sue the government for damages because of actions that violated a person’s state constitutional rights. The law covers state and local governments, commissions, agencies and branches of government funded with public money.
The Court’s ruling came in a case involving a horse trainer, Bradley Bolen, who sued the New Mexico Racing Commission over a disciplinary action against him after he argued with one of the commission’s racing stewards about a licensing matter. An evidentiary hearing was conducted and a panel of three stewards found Bolen’s conduct violated a racing regulation. Bolen sued under the CRA, alleging that the horse racing regulatory agency retaliated against him for exercising his free speech rights.
A district court rejected the commission’s arguments that it was immune to Bolen’s damage claim because it was performing a quasi-judicial function in its disciplinary proceeding. The commission challenged the decision, and the Court of Appeals agreed with the agency that judicial immunity was available as a defense to the civil rights claim. Bolen took the case to the Supreme Court.
The Court held that “judicial immunity, in certain circumstances, may extend to individuals and governmental entities performing quasi-judicial functions in the executive branch.” The justices returned the case to the district court for further proceedings to determine whether the commission was entitled to immunity from Bolen’s civil rights claim based on the facts in the matter and the legal guidance outlined in today’s opinion.
The justices established a legal framework for courts to follow in determining whether administrative functions warrant immunity from damage lawsuits because the proceedings are sufficiently judicial in nature.
“In addition to determining that immunity attaches to an adjudicatory proceeding, a court must also consider whether the conduct challenged in the claim is judicial in nature. Judicial immunity protects individuals and governmental entities from liability when functioning as an ‘arm of the court’ or, in other words, when performing a function that is integral to a judicial or quasi-judicial proceeding,” the Court wrote.
“We, therefore, require courts addressing questions of judicial immunity in the context of an adjudicatory proceeding in the executive branch to consider both (1) whether the adjudicatory proceeding shares enough characteristics of the judicial process to warrant the extension of judicial immunity to the proceeding and (2) whether the conduct at issue consists of a judicial function,” the Court wrote in an opinion by Justice Briana H. Zamora.
“We also emphasize that judicial immunity should extend no further than necessary to achieve the policy goals of protecting independent decision-making and ensuring the integrity of an established adjudicatory process,” the Court stated.
The justices explained, “A court considering a public body’s entitlement to judicial immunity should, therefore, carefully parse the challenged conduct to determine whether and to what extent that conduct consists of a judicial function. Judicial immunity will protect a public body from liability only when the nature of the proceeding and the nature of the challenged conduct merit absolute protection from suit.”