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 self-represented litigant and inmate at Central New Mexico Correctional Facility, filed tort claims against the facility and various employees. The claims arose from an incident in September 2017, where the Plaintiff fell down a flight of stairs during a seizure while being escorted from the shower to his cell. The Plaintiff alleged that the Defendants were aware of his medical condition but failed to monitor his seizure medication levels or place him in a lower-level cell. Additionally, the Plaintiff claimed that corrections officers used excessive force against him following his fall (para 1).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff: Argued that Defendants knew of his medical condition but failed to monitor his seizure medication levels or place him in a cell on the lower level. Also claimed that corrections officers used excessive force against him following his fall (para 1).
• Defendants: Filed a motion for summary judgment, which was granted in part and denied in part by the district court, and a motion to dismiss Plaintiff’s excessive force claims, which was granted by the district court (para 2).

Legal Issues

• Whether the district court erred in dismissing the Plaintiff's excessive force claims on the basis that corrections officers are not considered law enforcement officers under the Tort Claims Act (TCA), thereby not waiving immunity for alleged torts committed by them (paras 5-8).

Disposition

• The Court of Appeals affirmed the district court's decision to dismiss the Plaintiff's excessive force claims (para 9).

Reasons

• J. Miles Hanisee, with Judges Megan P. Duffy and Zachary A. Ives concurring, held that the Plaintiff, despite being a pro se litigant, is held to the same standards as litigants with counsel, including the requirement to provide clear arguments and citations to relevant authority in his briefs (paras 2-3). The Court noted that the Plaintiff's reply brief, while more clearly articulating assertions of error regarding the dismissal of his excessive force claims, could not be fully considered as it raised issues not presented in the initial brief (para 4). The Court concluded that corrections officers were not considered law enforcement officers under the version of Section 41-4-12 of the TCA in effect at the time of the incident and when the Plaintiff filed his complaints. Therefore, there was no waiver of immunity for the alleged torts, and the district court did not err in dismissing the Plaintiff's excessive force claims (paras 5-8).