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

• A group of former students enrolled in Doña Ana Community College's nursing program sued the Board of Regents of New Mexico State University after the program lost its accreditation from the National League of Nursing Accrediting Commission before they completed their studies. The college had provided written documents stating the program was nationally accredited at the time of their enrollment (para 1).

Procedural History

• District Court of Doña Ana County, Jerry H. Ritter Jr., District Judge: Denied Defendant’s motion for summary judgment on Plaintiffs’ breach of contract claim.

Parties' Submissions

• Plaintiffs-Appellees: Argued that a valid written contract existed between them and the Defendant, which promised a nationally accredited education in nursing in exchange for their enrollment and tuition. They based their claim on the offer letter, student handbook, and a handbook acknowledgment form they were required to sign, which they believed collectively constituted a valid written contract (para 2).
• Defendant-Appellant: Contended that it was immune under NMSA 1978, Section 37-1-23(A) (1976), arguing that Plaintiffs’ claim was not based on a “valid written contract” and therefore, the governmental entity should be granted immunity from actions based on contract except those based on a valid written contract (para 1).

Legal Issues

• Whether the written documents regarding accreditation relied upon by Plaintiffs constitute a valid written contract under Section 37-1-23(A), thereby waiving the Defendant's immunity from the breach of contract claim (para 1).

Disposition

• The Court of Appeals of New Mexico held that the offer letter, the handbook, and the handbook acknowledgment form do not constitute a valid written contract under Section 37-1-23(A) that contractually obligated the Defendant to provide a nationally accredited education to Plaintiffs. The court reversed the district court's decision and remanded with instructions to enter summary judgment in favor of the Defendant (para 20).

Reasons

• Per Jonathan B. Sutin, with concurrence from Linda M. Vanzi and Julie J. Vargas, the court reasoned that the documents in question did not meet the criteria for a valid written contract as required to waive immunity under Section 37-1-23(A). The offer letter did not mention accreditation or imply an agreement to provide a nationally accredited education. The court found that the handbook and acknowledgment form, while containing information about accreditation, did not explicitly promise or obligate the Defendant to maintain such accreditation. The court distinguished this case from others where implied contracts were found based on more explicit promises or obligations. It concluded that the Plaintiffs could not reasonably expect the documents to constitute a valid written contract guaranteeing a nationally accredited education, thus, the Defendant remained immune under Section 37-1-23(A) (paras 15-19).