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 Corrections Department (NMCD) erroneously released inmate Christopher Blattner before he completed his sentence. Approximately six months after his release, Blattner murdered Katherine Paquin. The Estate of Katherine Paquin filed a lawsuit claiming that NMCD negligently operated a public facility by failing to maintain records ensuring inmates served their full sentences, thus creating a danger to the public (paras 1 and 4).
Procedural History
- District Court: Granted summary judgment in favor of NMCD, concluding that the building waiver did not apply to off-premises injuries (para 2).
- Sanders v. N.M. Corr. Dep’t, 2023-NMCA-030: The Court of Appeals reversed the district court's decision, holding that the building waiver is not geographically limited (para 2).
Parties' Submissions
- Defendants-Petitioners (NMCD): Argued that the building waiver does not apply to off-premises injuries and that their conduct constituted negligent performance of an administrative function, which is not covered by the waiver (paras 8 and 68).
- Plaintiff-Respondent (Estate of Katherine Paquin): Claimed that NMCD negligently operated a public facility by failing to maintain records, which led to the early release of Blattner and the subsequent murder of Paquin (para 7).
Legal Issues
- Does the building waiver under the New Mexico Tort Claims Act apply to waive NMCD's immunity for off-premises injuries caused by the negligent release of an inmate?
- Is the negligent release of prisoners considered an operation of a building within the meaning of the building waiver?
Disposition
- The Supreme Court of New Mexico affirmed the Court of Appeals' decision, concluding that the building waiver contains no geographical limitation and that the negligent release of prisoners may constitute operation of a building (para 3).
Reasons
Per Bacon J. (Thomson C.J., Bosson J., Biedscheid J., and Levy J. concurring):
The Court found that the building waiver under the New Mexico Tort Claims Act does not contain a geographical limitation, meaning it can apply to off-premises injuries (para 3). The Court reasoned that the waiver's purpose is to ensure public safety by requiring public employees to exercise reasonable care in operating and maintaining government-owned premises (para 68). The Court also clarified that the negligent release of prisoners, if sufficiently pleaded, may constitute the operation of a building under the waiver (para 3). The Court disavowed the "negligent performance of an administrative function" exception from Archibeque, emphasizing that the waiver should be interpreted to facilitate its remedial intentions (paras 74-75). The Court remanded the case for further proceedings consistent with this opinion (para 75).