N.M. Stat. » Chapter 22 — Public Schools
New Mexico Statutes

N.M. Stat. § 22-10-14 (2026)

Recompiled

✓ laws through the 2025 session (retrieved May 2026)
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ANNOTATIONS

Recompilations. — Laws 2003, ch. 153, § 72 recompiled former 22-10-14 NMSA 1978 as 22-10A-24 NMSA 1978, effective April 4, 2003.

Notes of Decisions
Cited in 18 cases (1 in the last 5 years), 1962–2021 · leading case: Swinney v. Deming Bd. of Educ., 873 P.2d 238 (N.M. 1994).
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Swinney v. Deming Bd. of Educ., 873 P.2d 238 (N.M. 1994). · cites it 60× “[The Board's] purpose is to ensure that any decisions to terminate such employees comply with Section 22-10-14 NMSA as amended, 1978." The Manual, as applied to Swinney, requiring that the employee be given the opportunity to correct his deficiencies, amounts to de facto tenure…”
Franco v. Carlsbad Mun. Schs., 2001-NMCA-042, 28 P.3d 531. · cites it 20× “A copy of NMSA 1978, § 22-10-14 (1994), which defines the procedures for terminating non-certified school employees, was attached to the notice.”
Atencio v. Bd. of Educ. of Penasco, 655 P.2d 1012 (N.M. 1982). · cites it 2× “) More recently the New Mexico Legislature amended Section 22-10-14, N.M.Laws of 1979, ch. 86, § 1, regarding teacher tenure rights, by adding the following paragraph: B.”
New Mexico State Bd. of Educ. v. Bd. of Educ. of Alamogordo Pub. Sch. Dist. No. 1, 624 P.2d 530 (N.M. 1981). · cites it 2× “The interpretation of the statute adopted by the Local Board and the Court of Appeals would lead to inconsistencies and conflicts with other statutory provisions, such as Section 22-10-14, N.M.S.A. 1978 (Cum. Supp.”
Larsen v. Farmington Mun. Schs., 2010-NMCA-094, 242 P.3d 493. · cites it 2× “Section 22-10-14(D) (recompiled at Section 22-10A-24(D)).”
Aguilera v. Bd. of Educ. of the Hatch Valley Schs., 2006-NMSC-015, 132 P.3d 587. “, § 22-10-14 (termination), as enacted by 1967 N.”
In re Termination of Kibbe, 996 P.2d 419 (N.M. 1999). · cites it 2× “{4} The Elida school board notified Kibbe of the termination of his employment with Elida Public Schools on April 26, 1996, and pursuant to statute, NMSA 1978, § 22-10-14(C) (1994), Kibbe requested a written statement of the reasons for his termination.”
Kibbe v. Elida Sch. Dist., 2000-NMSC-006, 128 N.M. 629. · cites it 2× “{4} The Elida school board notified Kibbe of the termination of his employment with Elida Public Schools on April 26, 1996, and pursuant to statute, NMSA 1978, § 22-10-14(C) (1994), Kibbe requested a written statement of the reasons for his termination.”
Gadsden Fed'n of Teachers v. Bd. of Educ. of the Gadsden Indep. Sch. Dist., 920 P.2d 1052 (N.M. Ct. App. 1996). · cites it 3× “See §§ 22-10-14; 22-10-14.1 (Cum.Supp.1995). Because the 1994 legislation stated no effective date and contained no “emergency clause” that would cause it to take effect immediately, the amendment went into effect on May 18,1994, ninety days after the adjournment of the…”
Giangreco v. Murlless, 1997-NMCA-061, 943 P.2d 532. · cites it 5× “Lacking hearing rights, nontenured teachers have no such need for advance notice.”
Naranjo v. Bd. of Educ. of the Espanola Pub. Schs., 891 P.2d 542 (N.M. 1995). · cites it 7× “33, § 22 (codified as amended at NMSA 1978, § 22-10-14 (Repl.Pamp.1993)). In addition, the legislature enacted a provision regarding employment contracts with certified school personnel, including both teachers and administrators.”
Santa Fe Pub. Schs. v. Romero, 2001-NMCA-103, 37 P.3d 100. “1 — as opposed to the termination provisions — Sections 22-10-14 and - 14.1 — apply. {12} A school board may discharge a certified school employee only for just cause.”
Show all 18 citing cases →
N.M. Stat. § 22-10-14(0): 1 case
Franco v. Carlsbad Mun. Schs., 2001-NMCA-042, 28 P.3d 531. “A copy of NMSA 1978, § 22-10-14 (1994), which defines the procedures for terminating non-certified school employees, was attached to the notice.”
N.M. Stat. § 22-10-14(A): 1 case
Giangreco v. Murlless, 1997-NMCA-061, 943 P.2d 532. “Lacking hearing rights, nontenured teachers have no such need for advance notice.”
N.M. Stat. § 22-10-14(B): 1 case
Naranjo v. Bd. of Educ. of the Espanola Pub. Schs., 891 P.2d 542 (N.M. 1995). “33, § 22 (codified as amended at NMSA 1978, § 22-10-14 (Repl.Pamp.1993)). In addition, the legislature enacted a provision regarding employment contracts with certified school personnel, including both teachers and administrators.”
N.M. Stat. § 22-10-14(C): 2 cases
In re Termination of Kibbe, 996 P.2d 419 (N.M. 1999). “{4} The Elida school board notified Kibbe of the termination of his employment with Elida Public Schools on April 26, 1996, and pursuant to statute, NMSA 1978, § 22-10-14(C) (1994), Kibbe requested a written statement of the reasons for his termination.”
Kibbe v. Elida Sch. Dist., 2000-NMSC-006, 128 N.M. 629. “{4} The Elida school board notified Kibbe of the termination of his employment with Elida Public Schools on April 26, 1996, and pursuant to statute, NMSA 1978, § 22-10-14(C) (1994), Kibbe requested a written statement of the reasons for his termination.”
N.M. Stat. § 22-10-14(D): 2 cases
Larsen v. Farmington Mun. Schs., 2010-NMCA-094, 242 P.3d 493. “Section 22-10-14(D) (recompiled at Section 22-10A-24(D)).”
Gadsden Fed'n of Teachers v. Bd. of Educ. of the Gadsden Indep. Sch. Dist., 920 P.2d 1052 (N.M. Ct. App. 1996). “See §§ 22-10-14; 22-10-14.1 (Cum.Supp.1995). Because the 1994 legislation stated no effective date and contained no “emergency clause” that would cause it to take effect immediately, the amendment went into effect on May 18,1994, ninety days after the adjournment of the…”
N.M. Stat. § 22-10-14(E): 1 case
Franco v. Carlsbad Mun. Schs., 2001-NMCA-042, 28 P.3d 531. “A copy of NMSA 1978, § 22-10-14 (1994), which defines the procedures for terminating non-certified school employees, was attached to the notice.”
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