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 sixteen-year-old Native American student at Cibola High School alleged that a teacher, Defendant Eastin, engaged in discriminatory acts by cutting off a portion of another Native American student's braided hair and referring to the Plaintiff as a "bloody Indian" during a Halloween event in 2018. The Plaintiff claimed these actions violated the New Mexico Human Rights Act's prohibitions against discrimination in public accommodations (paras 3-4).
Procedural History
- District Court: Dismissed the suit, finding that Albuquerque Public Schools and its public secondary schools are not "public accommodations" under the New Mexico Human Rights Act (para 3).
- Johnson v. Bd. of Educ. for Albuquerque Pub. Schs., 2023-NMCA-069: The Court of Appeals reversed the district court's decision, holding that a secondary public school is a public accommodation under the NMHRA (para 4).
Parties' Submissions
- Defendants: Argued that public schools are not public accommodations under the NMHRA and that the Court of Appeals erred in its interpretation and application of the Regents decision (paras 1, 16).
- Plaintiff: Asserted that Albuquerque Public Schools' educational services are open to all students and thus qualify as public accommodations under the NMHRA (para 13).
Legal Issues
- Did the Court of Appeals err in determining that a public school in New Mexico can be classified as a public accommodation under the NMHRA? (para 4)
- Did the Court of Appeals err in its interpretation and application of the Regents decision? (para 4)
Disposition
- The Supreme Court of New Mexico affirmed the Court of Appeals' decision, holding that a public school is a public accommodation under the NMHRA (para 29).
Reasons
Per Thomson, Chief Justice (Vigil, Bacon, Vargas, and Zamora JJ. concurring):
The Court affirmed that the plain language of the NMHRA defines a public school as a public accommodation, subjecting it to suit for discriminatory conduct. The Court overruled the Regents decision, which incorrectly held that a public university's academic program administration was not a public accommodation. The Court emphasized that the NMHRA's language and legislative history support the inclusion of public schools as public accommodations, rejecting the argument that such institutions must be commercial businesses. The Court also noted that excluding public schools from the NMHRA would leave students without a remedy for discrimination not resulting in physical injury or property damage (paras 1-29).