AI Generated Opinion Summaries

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 Plaintiff, a former doctoral student at New Mexico Institute of Mining and Technology (New Mexico Tech), was terminated from his program after conflicts with his doctoral committee and alleged threats made by him, which he denied. Following his termination, he filed a civil rights complaint and a lawsuit, which was dismissed. A settlement was reached, where the Plaintiff agreed not to sue in exchange for $6000 and the removal of certain language from his academic records. However, the Defendants later added "no degree earned" to his transcript, leading the Plaintiff to declare the settlement void and seek re-enrollment, which was denied. He then filed for a declaratory judgment that the settlement was void, which was dismissed for being time-barred (paras 2-4).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff: Argued that the settlement agreement was void ab initio due to its violation of public policy and that the statute of limitations did not apply to a contract that is void from the beginning. He also claimed racial discrimination and sought a declaratory judgment that the settlement agreement was void, invalid, and unenforceable (paras 6, 11).
• Defendants: Contended that the action was barred by the two-year statute of limitations for actions based on contract against governmental entities. They argued that the plaintiff's claim, being contract-based, was subject to this statute of limitations and thus should be dismissed as a matter of law (para 6).

Legal Issues

• Whether the plaintiff's declaratory judgment action is an action "based on contract" within the meaning of Section 37-1-23(A) and thus barred by the statute of limitations (para 7).
• Whether the plaintiff's cause of action falls within the ambit of Section 37-1-23’s grant of sovereign immunity (para 7).
• Whether the statute of limitations is inapplicable with respect to the individual Defendants (para 11).

Disposition

• The court affirmed the district court's dismissal of the Plaintiff's claim, finding it was time-barred by the two-year statute of limitations for actions based on contract against governmental entities (para 1).

Reasons

• B. Zamora, J., with Jacqueline R. Medina, J., and Shammara H. Henderson, J., concurring, held that the plaintiff's action sought an interpretation of a settlement agreement against a governmental entity, which is considered a contract subject to contract law. Thus, the action was deemed "based on contract" and subject to the two-year statute of limitations. The court found that the plaintiff's claim accrued in October 2015 when he first alleged violations of the settlement agreement and declared it void. Since the complaint was filed in April 2018, it was outside the two-year limitation period. The court also rejected the plaintiff's argument regarding the inapplicability of the statute of limitations to individual defendants, noting it was not preserved for appeal. The court concluded that the plaintiff's contract-based cause of action was barred by the statute of limitations, affirming the district court's ruling without reaching the issue of whether the Settlement Agreement is void ab initio (paras 5-15).