defense of qualified immunity (New Mexico) · Go Syfert
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defense of qualified immunity in New Mexico

10 New Mexico opinions name it 2 courts 1964–2024 1 in the last five years

The cases below were cited by New Mexico courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Carrillo v. Rostrogreen
nm · 1992 · cited in 3 New Mexico opinions naming this issue, 1999–2004
2 sentences

2004Carrillo, 114 N.M. at 614-16 , 845 P.2d at 137-39 ; Chavez v. Bd. of County Comm’rs, 2001-NMCA-065, ¶ 10 , 130 N.M. 753 , 31 P.3d 1027 ; Sugg v. Albuquerque Pub.

2003See id. at 610, 616-17, 845 P.2d at 133, 139-40 . {32} Carrillo was a civil rights action in which defendant school board members raised the defense of qualified immunity.

23
State v. Smithgreen
nm · 2004 · cited in 1 New Mexico opinions naming this issue, 2024–2024
1 sentence

2024See Smith, 2004-NMSC-032, ¶ 8 . {17} Section 41-4A-12, which is titled “Prospective application,” states, “Claims arising solely from acts or omissions that occurred prior to July 1, 2021 may not be brought pursuant to the [CRA].” Plaintiffs acknowledge their claims are based on actions before July 1, 2021, but assert that “[n]o legislative comment or any part of the [CRA] speaks to whether the defense of qualified immunity has prospective application only.

11
Rebecca Warner and Pamela Ann Laxton v. Grand County, Ron Richmond, James B. Nyland and Robin A. Parkergreen
ca10 · 1995 · cited in 1 New Mexico opinions naming this issue, 2020–2020
2 sentences

2020Warner, 57 F.3d at 967 (holding that “a private individual who performs a government function pursuant to a state order or request is entitled to qualified immunity if a state official would have been entitled to such immunity had he performed the function himself”); Rodriques, 950 F.2d at 815 (holding that a doctor was entitled to the defense of qualified immunity where his liability was “asserted upon the fact that he operated as a state actor in conducting a search procedure traditionally within the power of the [s]tate”).

2020Warner, 57 F.3d at 967 (holding that “a private individual who performs a government function pursuant to a state order or request is entitled to qualified immunity if a state official would have been entitled to such immunity had he performed the function himself”); Rodriques, 950 F.2d at 815 (holding that a doctor was entitled to the defense of qualified immunity where his liability was “asserted upon the fact that he operated as a state actor in conducting a search procedure traditionally within the power of the [s]tate”).

11
Shirley Mello Rodriques v. Joseph Furtadogreen
ca1 · 1991 · cited in 1 New Mexico opinions naming this issue, 2020–2020
2 sentences

2020Warner, 57 F.3d at 967 (holding that “a private individual who performs a government function pursuant to a state order or request is entitled to qualified immunity if a state official would have been entitled to such immunity had he performed the function himself”); Rodriques, 950 F.2d at 815 (holding that a doctor was entitled to the defense of qualified immunity where his liability was “asserted upon the fact that he operated as a state actor in conducting a search procedure traditionally within the power of the [s]tate”).

2020Warner, 57 F.3d at 967 (holding that “a private individual who performs a government function pursuant to a state order or request is entitled to qualified immunity if a state official would have been entitled to such immunity had he performed the function himself”); Rodriques, 950 F.2d at 815 (holding that a doctor was entitled to the defense of qualified immunity where his liability was “asserted upon the fact that he operated as a state actor in conducting a search procedure traditionally within the power of the [s]tate”).

11
Gross v. Pirtlegreen
ca10 · 2001 · cited in 1 New Mexico opinions naming this issue, 2006–2006
1 sentence

2006Cockrell, 1999-NMCA-073, ¶ 8 , 127 N.M. 478 , 983 P.2d 427 (internal quotation marks omitted); see also Gross v. Pirtle, 245 F.3d 1151, 1155 (10th Cir.2001) (stating that to defeat qualified immunity, a plaintiff must satisfy a “heavy two-part burden”). {13} We analyze the defense of qualified immunity in two steps.

11
Firestone Tire & Rubber Co. v. Risjordgreen
scotus · 1981 · cited in 1 New Mexico opinions naming this issue, 2003–2003
1 sentence

2003See id. at 610, 616-17, 845 P.2d at 133, 139-40 . {32} Carrillo was a civil rights action in which defendant school board members raised the defense of qualified immunity.

11
Romero v. Sanchezgreen
nm · 1995 · cited in 1 New Mexico opinions naming this issue, 1999–1999
2 sentences

1999DISCUSSION The Qualified Immunity Defense and Summary Judgment {8} Government officials performing discretionary functions are entitled to qualified immunity from suit under § 1983 as long as “their conduct [did] not violate clearly established [federal] statutory or constitutional rights of which a reasonable person would have known.” Harlow v. Fitzgerald, 457 U.S. 800, 818 , 102 S.Ct. 2727 , 73 L.Ed.2d 396 (1982); accord Romero v. Sanchez, 119 N.M. 690, 692 , 895 P.2d 212, 214 (1995); Kennedy v. Dexter Consol.

1999DISCUSSION The Qualified Immunity Defense and Summary Judgment {8} Government officials performing discretionary functions are entitled to qualified immunity from suit under § 1983 as long as “their conduct [did] not violate clearly established [federal] statutory or constitutional rights of which a reasonable person would have known.” Harlow v. Fitzgerald, 457 U.S. 800, 818 , 102 S.Ct. 2727 , 73 L.Ed.2d 396 (1982); accord Romero v. Sanchez, 119 N.M. 690, 692 , 895 P.2d 212, 214 (1995); Kennedy v. Dexter Consol.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Mexico. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
Doe v. Leach green
nmctapp · 1999
2 sentences

2020“For a right to be clearly established, the contours of the right must be sufficiently clear that a reasonable official would understand that what he is doing violates that right.” Doe v. Leach, 1999-NMCA- 117, ¶ 10, 128 N.M. 28 , 988 P.2d 1252 (alteration, internal quotation marks, and citation omitted).

2020“For a right to be clearly established, the contours of the right must be sufficiently clear that a reasonable official would understand that what he is doing violates that right.” Doe v. Leach, 1999-NMCA- 117, ¶ 10, 128 N.M. 28 , 988 P.2d 1252 (alteration, internal quotation marks, and citation omitted).

12020–2020
Benavidez v. Shutiva green
nmctapp · 2015
2 sentences

2020The parties do not dispute that Beesley functioned as a state actor here. {12} Once a defense of qualified immunity has been raised by a defendant, in order to defeat it, the “plaintiff must demonstrate that (1) the defendant’s alleged conduct violated a constitutional or statutory right, and (2) the right was clearly established at the time of the [alleged] conduct.” Benavidez v. Shutiva, 2015-NMCA-065, ¶ 6 , 350 P.3d 1234 (internal quotation marks and citation omitted).

2020The parties do not dispute that Beesley functioned as a state actor here. {12} Once a defense of qualified immunity has been raised by a defendant, in order to defeat it, the “plaintiff must demonstrate that (1) the defendant’s alleged conduct violated a constitutional or statutory right, and (2) the right was clearly established at the time of the [alleged] conduct.” Benavidez v. Shutiva, 2015-NMCA-065, ¶ 6 , 350 P.3d 1234 (internal quotation marks and citation omitted).

12020–2020
King v. Allstate Insurance green
nmctapp · 2004
2 sentences

2008Co., 2004-NMCA-031, ¶16 , 135 N.M. 206 , 86 P.3d 631 (citations omitted).

2008Co., 2004-NMCA-031, ¶16 , 135 N.M. 206 , 86 P.3d 631 (citations omitted).

12008–2008
Cockrell v. Board of Regents of New Mexico State University green
nmctapp · 1999
2 sentences

2006Cockrell, 1999-NMCA-073, ¶ 8 , 127 N.M. 478 , 983 P.2d 427 (internal quotation marks omitted); see also Gross v. Pirtle, 245 F.3d 1151, 1155 (10th Cir.2001) (stating that to defeat qualified immunity, a plaintiff must satisfy a “heavy two-part burden”). {13} We analyze the defense of qualified immunity in two steps.

2006Cockrell, 1999-NMCA-073, ¶ 8 , 127 N.M. 478 , 983 P.2d 427 (internal quotation marks omitted); see also Gross v. Pirtle, 245 F.3d 1151, 1155 (10th Cir.2001) (stating that to defeat qualified immunity, a plaintiff must satisfy a “heavy two-part burden”). {13} We analyze the defense of qualified immunity in two steps.

12006–2006
Garcia-Montoya v. State Treasurer's Office green
nm · 2001
2 sentences

2006In the first step, a court “must first determine whether the plaintiff has alleged the deprivation of an actual constitutional right at all.” Garcia-Montoya, 2001-NMSC-003, ¶ 9 , 130 N.M. 25 , 16 P.3d 1084 (internal quotation marks and citation omitted); accord Kennedy v. Dexter Consol.

2006In the first step, a court “must first determine whether the plaintiff has alleged the deprivation of an actual constitutional right at all.” Garcia-Montoya, 2001-NMSC-003, ¶ 9 , 130 N.M. 25 , 16 P.3d 1084 (internal quotation marks and citation omitted); accord Kennedy v. Dexter Consol.

12006–2006
Chavez v. Board of County Commissioners green
nmctapp · 2001
2 sentences

2004Carrillo, 114 N.M. at 614-16 , 845 P.2d at 137-39 ; Chavez v. Bd. of County Comm’rs, 2001-NMCA-065, ¶ 10 , 130 N.M. 753 , 31 P.3d 1027 ; Sugg v. Albuquerque Pub.

2004Carrillo, 114 N.M. at 614-16 , 845 P.2d at 137-39 ; Chavez v. Bd. of County Comm’rs, 2001-NMCA-065, ¶ 10 , 130 N.M. 753 , 31 P.3d 1027 ; Sugg v. Albuquerque Pub.

12004–2004
Harlow v. Fitzgerald green
scotus · 1982
2 sentences

1999DISCUSSION The Qualified Immunity Defense and Summary Judgment {8} Government officials performing discretionary functions are entitled to qualified immunity from suit under § 1983 as long as “their conduct [did] not violate clearly established [federal] statutory or constitutional rights of which a reasonable person would have known.” Harlow v. Fitzgerald, 457 U.S. 800, 818 , 102 S.Ct. 2727 , 73 L.Ed.2d 396 (1982); accord Romero v. Sanchez, 119 N.M. 690, 692 , 895 P.2d 212, 214 (1995); Kennedy v. Dexter Consol.

1999DISCUSSION The Qualified Immunity Defense and Summary Judgment {8} Government officials performing discretionary functions are entitled to qualified immunity from suit under § 1983 as long as “their conduct [did] not violate clearly established [federal] statutory or constitutional rights of which a reasonable person would have known.” Harlow v. Fitzgerald, 457 U.S. 800, 818 , 102 S.Ct. 2727 , 73 L.Ed.2d 396 (1982); accord Romero v. Sanchez, 119 N.M. 690, 692 , 895 P.2d 212, 214 (1995); Kennedy v. Dexter Consol.

11999–1999
Rutan v. Republican Party of Illinois green
scotus · 1990
2 sentences

1995CONCLUSION "To the victor belong only those spoils that may be constitutionally obtained." Rutan, 497 U.S. at 64 , 110 S.Ct. at 2731 .

1995CONCLUSION "To the victor belong only those spoils that may be constitutionally obtained." Rutan, 497 U.S. at 64 , 110 S.Ct. at 2731 .

11995–1995
Cohen v. Beneficial Industrial Loan Corp. green
scotus · 1949
2 sentences

1992Plaintiff sued under 42 U.S.C. § 1983 (1988) for defendants’ alleged violation of her First and Fourteenth Amendment right to speak at a public meeting. 1 The procedural question, which we must resolve first because it relates to our jurisdiction to hear this appeal, is whether the trial court’s denial of summary judgment on defendants’ qualified immunity defense is reviewable, before trial, under the collateral order doctrine adopted by the United States Supreme Court in Cohen v. Beneficial Industrial Loan Corp., 337 U.S. 541 , 69 S.Ct. 1221 , 93 L.Ed. 1528 (1949).

1992Plaintiff sued under 42 U.S.C. § 1983 (1988) for defendants’ alleged violation of her First and Fourteenth Amendment right to speak at a public meeting. 1 The procedural question, which we must resolve first because it relates to our jurisdiction to hear this appeal, is whether the trial court’s denial of summary judgment on defendants’ qualified immunity defense is reviewable, before trial, under the collateral order doctrine adopted by the United States Supreme Court in Cohen v. Beneficial Industrial Loan Corp., 337 U.S. 541 , 69 S.Ct. 1221 , 93 L.Ed. 1528 (1949).

11992–1992
Gomez v. BOARD OF ED. OF DULCE IND. SCH. DIST. NO 21 green
nm · 1973
2 sentences

1992Id. 85 N.M. at 716 , 516 P.2d at 687 .

1992Id. 85 N.M. at 716 , 516 P.2d at 687 .

11992–1992
Mitchell v. Forsyth green
scotus · 1985
2 sentences

1992Defendants based this assertion on Mitchell v. Forsyth, in which the Supreme Court held that a denial of qualified immunity on a Section 1983 claim is final and appealable under the collateral order doctrine. 472 U.S. at 530 , 105 S.Ct. at 2817 .

1992Defendants based this assertion on Mitchell v. Forsyth, in which the Supreme Court held that a denial of qualified immunity on a Section 1983 claim is final and appealable under the collateral order doctrine. 472 U.S. at 530 , 105 S.Ct. at 2817 .

11992–1992
Colbert v. Journal Publishing Co. green
· 1914
2 sentences

1964Appellant cites Colbert v. Journal Publishing Company, 19 N.M. 156 , 142 P. 146 ; Ward v. Ares, 29 N.M. 418 , 223 P. 766 ; and White v. Morrison, 62 N.M. 47 , 304 P.2d 572 , in support of this contention.

1964Appellant cites Colbert v. Journal Publishing Company, 19 N.M. 156 , 142 P. 146 ; Ward v. Ares, 29 N.M. 418 , 223 P. 766 ; and White v. Morrison, 62 N.M. 47 , 304 P.2d 572 , in support of this contention.

11964–1964
Ward v. Ares green
nm · 1924
2 sentences

1964Appellant cites Colbert v. Journal Publishing Company, 19 N.M. 156 , 142 P. 146 ; Ward v. Ares, 29 N.M. 418 , 223 P. 766 ; and White v. Morrison, 62 N.M. 47 , 304 P.2d 572 , in support of this contention.

1964Appellant cites Colbert v. Journal Publishing Company, 19 N.M. 156 , 142 P. 146 ; Ward v. Ares, 29 N.M. 418 , 223 P. 766 ; and White v. Morrison, 62 N.M. 47 , 304 P.2d 572 , in support of this contention.

11964–1964
White v. Morrison green
nm · 1956
2 sentences

1964Appellant cites Colbert v. Journal Publishing Company, 19 N.M. 156 , 142 P. 146 ; Ward v. Ares, 29 N.M. 418 , 223 P. 766 ; and White v. Morrison, 62 N.M. 47 , 304 P.2d 572 , in support of this contention.

1964Appellant cites Colbert v. Journal Publishing Company, 19 N.M. 156 , 142 P. 146 ; Ward v. Ares, 29 N.M. 418 , 223 P. 766 ; and White v. Morrison, 62 N.M. 47 , 304 P.2d 572 , in support of this contention.

11964–1964

Statutes the citing opinions construe

USC § 42u.s.c.1983 (6)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 46 (1944–2024) TX 35 (1978–2024) OH 34 (1980–2026) NC 29 (1963–2022) NJ 20 (1975–2025) AL 18 (1991–2025) CA 15 (1921–2017) MA 14 (1991–2026) CT 12 (1992–2009) MD 11 (1959–2020) FL 11 (1981–2010) NM 10 (1964–2024) MI 9 (1987–2019) PA 9 (1938–2025) MO 9 (1954–2000) DC 8 (1970–2024) WV 8 (1943–2023) CO 7 (1990–2002) WY 7 (1989–2021) SC 7 (1962–2015) LA 6 (1977–2008) IA 6 (1972–2013) MS 6 (1991–2005) WI 6 (1987–2000) AZ 6 (1970–2011) SD 6 (1993–2021) TN 5 (1996–2011) GA 5 (1992–2015) WA 4 (1978–2024) KS 4 (1994–2013) VA 4 (1985–2014) IN 4 (1977–1989) OK 4 (1981–2017) OR 4 (1960–2012) ME 3 (1998–2023) ID 3 (1987–2004) IL 3 (1975–2006) AR 3 (1987–2013) NE 2 (1931–1999) VT 2 (2024–2024) MN 2 (1994–1997) RI 2 (1992–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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