continuing violation (New Mexico) · Go Syfert
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continuing violation in New Mexico

8 New Mexico opinions name it 2 courts 1995–2018 0 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 (11)

CaseFollowedCited
Tull v. City of Albuquerquegreen
nmctapp · 1995 · cited in 4 New Mexico opinions naming this issue, 2013–2013
2 sentences

2013This Court has previously rejected the continuing violation theory in the context of employment contracts where there has been a “single-wrong with continuing effects.” Tull v. City of Albuquerque, 120 N.M. 829, 830 , 907 P.2d 1010, 1011 (Ct.App. 1995) (internal quotation marks omitted).

2013This Court has previously rejected the continuing violation theory in the context of employment contracts where there has been a “single-wrong with continuing effects.” Tull v. City of Albuquerque, 120 N.M. 829, 830 , 907 P.2d 1010, 1011 (Ct.App. 1995) (internal quotation marks omitted).

44
Novella v. Westchester Countygreen
ca2 · 2011 · cited in 3 New Mexico opinions naming this issue, 2013–2013
2 sentences

2013Still other courts have refused to apply it where the plaintiff’s “claims are based on a single decision that results in lasting negative effects.” Novella v. Westchester Cnty., 661 F.3d 128, 146 (2d Cir. 2011) (internal quotation marks and citation omitted); see Schultz v. Texaco Inc., 127 F. Supp. 2d 443, 447 (S.D.N.Y. 2001) (“[T]he mere fact that the effects of a single, wrongful act continue to be felt over a period of time does not render that single, wrongful act a ‘continuing violation.’ ”). {25} This Court has previously rejected the continuing violation theory in the context of employ

2013Still other courts have refused to apply it where the plaintiff’s “claims are based on a single decision that results in lasting negative effects.” Novella v. Westchester Cnty., 661 F.3d 128, 146 (2d Cir. 2011) (internal quotation marks and citation omitted); see Schultz v. Texaco Inc., 127 F. Supp. 2d 443, 447 (S.D.N.Y. 2001) (“[T]he mere fact that the effects of a single, wrongful act continue to be felt over a period of time does not render that single, wrongful act a ‘continuing violation.’ ”). {25} This Court has previously rejected the continuing violation theory in the context of employ

33
Schultz v. Texaco Inc.green
nysd · 2001 · cited in 3 New Mexico opinions naming this issue, 2013–2013
2 sentences

2013Still other courts have refused to apply it where the plaintiff’s “claims are based on a single decision that results in lasting negative effects.” Novella v. Westchester Cnty., 661 F.3d 128, 146 (2d Cir. 2011) (internal quotation marks and citation omitted); see Schultz v. Texaco Inc., 127 F. Supp. 2d 443, 447 (S.D.N.Y. 2001) (“[T]he mere fact that the effects of a single, wrongful act continue to be felt over a period of time does not render that single, wrongful act a ‘continuing violation.’ ”). {25} This Court has previously rejected the continuing violation theory in the context of employ

2013Still other courts have refused to apply it where the plaintiff’s “claims are based on a single decision that results in lasting negative effects.” Novella v. Westchester Cnty., 661 F.3d 128, 146 (2d Cir. 2011) (internal quotation marks and citation omitted); see Schultz v. Texaco Inc., 127 F. Supp. 2d 443, 447 (S.D.N.Y. 2001) (“[T]he mere fact that the effects of a single, wrongful act continue to be felt over a period of time does not render that single, wrongful act a ‘continuing violation.’ ”). {25} This Court has previously rejected the continuing violation theory in the context of employ

33
Concha v. Sanchezgreen
nm · 2011 · cited in 1 New Mexico opinions naming this issue, 2018–2018
1 sentence

2018See id.

11
Gonzales v. New Mexico Department of Healthgreen
nm · 2000 · cited in 1 New Mexico opinions naming this issue, 2010–2010
2 sentences

2010Nevertheless, like hostile environment cases, cases involving retaliation resulting in constructive discharge may “involve repeated conduct over days or years and individual acts of [retaliation] may not be separately actionable.” Id; see also Gonzales v. New Mexico Dep’t of Health, 2000-NMSC-029 , ¶¶23, 25, 129 N.M. 586 , 11 P.3d 550 (holding that a jury could reasonably conclude that the evidence supported the plaintiffs claim of retaliation based on evidence that the plaintiff was criticized, called a troublemaker, transferred to a more remote building, not informed of, and denied access to

2010Nevertheless, like hostile environment cases, cases involving retaliation resulting in constructive discharge may “involve repeated conduct over days or years and individual acts of [retaliation] may not be separately actionable.” Id; see also Gonzales v. New Mexico Dep’t of Health, 2000-NMSC-029 , ¶¶23, 25, 129 N.M. 586 , 11 P.3d 550 (holding that a jury could reasonably conclude that the evidence supported the plaintiffs claim of retaliation based on evidence that the plaintiff was criticized, called a troublemaker, transferred to a more remote building, not informed of, and denied access to

11
Gallegos v. City of Denvergreen
ca10 · 1994 · cited in 1 New Mexico opinions naming this issue, 2006–2006
1 sentence

2006See Lee v. Rocky Mountain UFCW Unions & Employers Trust Pension Plan, No. 92-1308, 13 F.3d 405 , 1993 WL 482951, at *1 (10th Cir. Nov.23, 1993) (unpublished) (“[W]hile the plaintiff in Aldrich alleged specific facts that supported tolling the statute of limitations, Ms. Lee merely makes the bald-faced allegation that if she were given the opportunity to develop additional facts through discovery, she might be able to prove a continuing violation or inequitable conduct by Rocky Mountain.

11
Fern C. Lee v. Rocky Mountain Ufcw Unions and Employers Trust Pension Plangreen
ca10 · 1993 · cited in 1 New Mexico opinions naming this issue, 2006–2006
1 sentence

2006See Lee v. Rocky Mountain UFCW Unions & Employers Trust Pension Plan, No. 92-1308, 13 F.3d 405 , 1993 WL 482951, at *1 (10th Cir. Nov.23, 1993) (unpublished) (“[W]hile the plaintiff in Aldrich alleged specific facts that supported tolling the statute of limitations, Ms. Lee merely makes the bald-faced allegation that if she were given the opportunity to develop additional facts through discovery, she might be able to prove a continuing violation or inequitable conduct by Rocky Mountain.

11
Arthur Taylor v. General Motors Corporation and Metropolitan Life Insurance Companygreen
ca6 · 1987 · cited in 1 New Mexico opinions naming this issue, 1995–1995
1 sentence

1995See, e.g., Kyriakopoulos v. George Washington Univ., 866 F.2d 438, 443 (D.C.Cir.1989) (failure to cure a previous breach of contract does not constitute a new breach); Taylor v. General Motors Corp., 826 F.2d 452, 456 (6th Cir.1987) (proper focus is upon the time of the failure to promote, not upon the time of the consequences); Hollinger-Haye v. Harrison Western/Franki-Denys, 729 F.Supp. 1397, 1399 (D.D.C.1990) (mem.) (denial of a promotion alone does not constitute a continuing violation); Prouty v. National R.R.

11
Nicholas Kyriakopoulos v. George Washington Universitygreen
cadc · 1989 · cited in 1 New Mexico opinions naming this issue, 1995–1995
1 sentence

1995See, e.g., Kyriakopoulos v. George Washington Univ., 866 F.2d 438, 443 (D.C.Cir.1989) (failure to cure a previous breach of contract does not constitute a new breach); Taylor v. General Motors Corp., 826 F.2d 452, 456 (6th Cir.1987) (proper focus is upon the time of the failure to promote, not upon the time of the consequences); Hollinger-Haye v. Harrison Western/Franki-Denys, 729 F.Supp. 1397, 1399 (D.D.C.1990) (mem.) (denial of a promotion alone does not constitute a continuing violation); Prouty v. National R.R.

11
Prouty v. National Railroad Passenger Corp.green
dcd · 1983 · cited in 1 New Mexico opinions naming this issue, 1995–1995
1 sentence

1995Passenger Corp., 572 F.Supp. 200, 207 (D.D.C.1983) (mem.) (no continuing wrong where all of plaintiffs allegations stem from defendant’s failure to promote).

11
Hollinger-Haye v. Harrison Western/Franki-Denysgreen
dcd · 1990 · cited in 1 New Mexico opinions naming this issue, 1995–1995
1 sentence

1995See, e.g., Kyriakopoulos v. George Washington Univ., 866 F.2d 438, 443 (D.C.Cir.1989) (failure to cure a previous breach of contract does not constitute a new breach); Taylor v. General Motors Corp., 826 F.2d 452, 456 (6th Cir.1987) (proper focus is upon the time of the failure to promote, not upon the time of the consequences); Hollinger-Haye v. Harrison Western/Franki-Denys, 729 F.Supp. 1397, 1399 (D.D.C.1990) (mem.) (denial of a promotion alone does not constitute a continuing violation); Prouty v. National R.R.

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 (1)

CaseCitedYears
Ulibarri v. State of New Mexico Corrections Academy green
nm · 2006
2 sentences

2010Consequently, “if one act contributing to a [retaliation] claim [based on a series of actions and not a single, discrete act] occurred within the filing period, all acts creating the [retaliation claim] may be considered.” Ulibarri, 2006-NMSC-009, ¶ 10 , 139 N.M. 193 , 131 P.3d 43 . {13} We must therefore consider whether Plaintiffs retaliation claim is based on a discrete act or on a cumulative series of acts.

2010Consequently, “if one act contributing to a [retaliation] claim [based on a series of actions and not a single, discrete act] occurred within the filing period, all acts creating the [retaliation claim] may be considered.” Ulibarri, 2006-NMSC-009, ¶ 10 , 139 N.M. 193 , 131 P.3d 43 . {13} We must therefore consider whether Plaintiffs retaliation claim is based on a discrete act or on a cumulative series of acts.

12010–2010

Statutes the citing opinions construe

NM § N.M. Stat. § 37-1-24 (5) NM § N.M. Stat. § 10-7C-1 (4)

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

CA 155 (1941–2026) NY 113 (1910–2026) TX 101 (1960–2025) IL 91 (1910–2026) NJ 86 (1971–2026) MA 60 (1971–2025) PA 49 (1932–2026) NC 32 (1969–2025) AL 30 (1984–2023) WA 30 (1984–2026) OH 25 (1995–2026) MD 24 (1972–2021) CT 24 (1987–2024) MO 22 (1980–2025) FL 21 (1974–2025) MN 21 (1983–2025) MI 19 (1972–2024) IA 18 (1990–2021) GA 18 (1940–2024) DC 17 (1980–2020) TN 17 (1995–2026) LA 16 (1979–2019) WV 14 (1981–2025) WI 13 (1924–2026) VA 12 (1999–2025) CO 12 (1989–2026) VT 11 (1996–2026) OK 11 (1916–2014) ME 9 (1996–2025) WY 8 (1939–2000) NM 8 (1995–2018) AZ 8 (2008–2021) KS 7 (1980–2025) NH 7 (2006–2016) OR 7 (1977–2023) DE 6 (2015–2024) IN 6 (1984–2023) RI 6 (2005–2026) MS 6 (1940–2018) ID 5 (1984–2008) AK 5 (1994–2022) MT 5 (1999–2022) NE 4 (1929–2007) VI 4 (2005–2024) SD 4 (1980–2000) KY 4 (1992–2023) SC 3 (2015–2018) UT 2 (1992–2019) ND 2 (2009–2020)

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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