Williams v. Mann
2017 NMCA 12
| N.M. Ct. App. | 2016Background
- NMHRA claim against Four Corners Family Dental, LLC tolled by federal action under 28 U.S.C. § 1367(d); NMHRA claim against Mann not tolled and dismissed; district court initially dismissed NMHRA claims as untimely against Four Corners and Mann; district court later held Defendants liable for $625 unpaid wages, doubled under MWA, plus interest and fees for wages but denied overtime; bench trial on overtime claim found Plaintiff exempt as bona fide administrative employee under MWA after applying DOL regulations; appellate court must review for proper tolling and correct legal standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of NMHRA claim against Four Corners | Tolling under 28 U.S.C. § 1367(d) preserved timing | Tolling only for post-dismissal supplemental state claims | NMHRA claim against Four Corners tolled and timely; reversal of dismissal |
| Timeliness of NMHRA claim against Mann | Amended state claim timely via relation back | No federal supplemental jurisdiction over Mann; untimely | NMHRA claim against Mann dismissed as untimely |
| Overtime claim under MWA | Plaintiff not exempt from overtime; should be paid | Plaintiff exempt as bona fide administrative employee | Plaintiff exempt; district court’s judgment affirmed on overtime claim |
| Standard of review and procedural posture for Rule 1-050 ruling | Error in using 1-050; requires new trial | Ruling can be upheld under de novo/clear error standard | No automatic reversal; standard applied appropriate to circumstances |
Key Cases Cited
- Luboyeski v. Hill, 117 N.M. 380 (1994-NMSC-032) (tolling and exhaustion principles under NMHRA)
- Gathman-Matotan Architects & Planners, Inc. v. State Dep’t of Fin. & Admin., 109 P.2d 411 (1990-NMSC-013) (tolling statutes and timely commenced actions)
- Valentine v. Bank of Albuquerque, 704 P.2d 1 (1985-NMSC-033) (exemption factors for administrative employee under MWA)
- Reeves v. Wimberly, 107 N.M. 231 (1988-NMCA-038) (preservation of issues on appeal and record doctrine)
- In re Adoption of Doe, 100 N.M. 764 (1984-NMSC-024) (preservation/notice issues in appellate review)