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Decision Information

Decision Content

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

  • The New Mexico Public Education Department charged Chad Skowronski, a science teacher, with engaging in inappropriate and improper sexual contact or behavior with a fourteen-year-old female. The alleged incident occurred at the home of the victim's godparents during an event attended by Skowronski, the victim, and her parents. Following the event, the victim and Skowronski slept in the living room, where the alleged contact took place (paras 2-3).

Procedural History

  • District Court of Santa Fe County: Affirmed the decision of the Secretary of the New Mexico Public Education Department revoking Skowronski's teaching license.
  • Court of Appeals of New Mexico: Affirmed the decision of the district court.

Parties' Submissions

  • Appellant (Skowronski): Argued that the Department erred in submitting his license revocation to the Secretary for final decision, the Secretary erred in substituting her own credibility findings for those of the hearing officer, the Department and the Secretary denied him due process of law, and the Secretary’s decision was not supported by substantial evidence (para 6).
  • Appellees (The New Mexico Public Education Department and Veronica C. Garcia): Contended that the Secretary had the authority to make the final revocation decision, the Secretary's deviation from the hearing officer's proposed findings was supported by a preponderance of the evidence, and the Secretary's decision was supported by substantial evidence (paras 18-20, 32-44).

Legal Issues

  • Whether the Secretary had constitutional or statutory authority to revoke a teaching license.
  • Whether the Secretary erred in substituting her own credibility findings for those of the hearing officer.
  • Whether the Department and the Secretary denied Skowronski due process of law.
  • Whether the Secretary’s decision was supported by substantial evidence.

Disposition

  • The Court of Appeals affirmed the decision of the district court, which had affirmed the Secretary's decision to revoke Skowronski's teaching license.

Reasons

  • Per Jonathan B. Sutin (Roderick T. Kennedy and Michael E. Vigil concurring): The court held that the Secretary had the authority to make the final revocation decision based on the interpretation of constitutional and statutory provisions. The court found no requirement for the Secretary to defer to the hearing officer's credibility determinations and determined that the Secretary's decision was supported by substantial evidence. The court also concluded that Skowronski was not deprived of due process, as the administrative procedure used did not create a risk of erroneous deprivation of Skowronski’s occupational license. The court rejected Skowronski's arguments regarding bias and the denial of further discovery, finding them unsupported by the record or law (paras 17-44).
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