Bolen v. N.M. Racing Comm'n

CourtNew Mexico Supreme Court
DecidedJune 2, 2025
StatusUnpublished

This text of Bolen v. N.M. Racing Comm'n (Bolen v. N.M. Racing Comm'n) is published on Counsel Stack Legal Research, covering New Mexico Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bolen v. N.M. Racing Comm'n, (N.M. 2025).

Opinion

The slip opinion is the first version of an opinion released by the Chief Clerk of the Supreme Court. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Chief Clerk for compliance with Rule 23- 112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion.

1 IN THE SUPREME COURT OF THE STATE OF NEW MEXICO

2 Opinion Number:

3 Filing Date: June 2, 2025

4 NO. S-1-SC-40427

5 BRAD BOLEN a/k/a BRADLEY 6 CARROL BOLEN,

7 Plaintiff-Petitioner,

8 v.

9 NEW MEXICO RACING COMMISSION; 10 and FABIAN LOPEZ, Records Custodian 11 for New Mexico Racing Commission,

12 Defendants-Respondents.

13 ORIGINAL PROCEEDING ON CERTIORARI 14 Joshua A. Allison, District Judge

15 L. Helen Bennett, P.C. 16 Linda Helen Bennett 17 Albuquerque, NM

18 for Petitioner

19 Jackson Loman Downey & Stevens-Block, P.C. 20 R. Eric Loman 21 Kara Y. Shair-Rosenfield 22 Albuquerque, NM

23 for Respondents 1 Kristen Greer Love 2 María Martínez Sánchez 3 Albuquerque, NM

4 for Amicus Curiae American Civil Liberties Foundation of New Mexico

5 Walker Boyd 6 Jeremy Farris 7 Albuquerque, NM

8 for Amicus Curiae New Mexico State Ethics Commission

9 Erin Lecocq, Agency Attorney 10 Santa Fe, NM

11 for Amicus Curiae New Mexico Public Regulation Commission

12 Brian VanDenzen 13 David Buchanan 14 Santa Fe, NM

15 for Amicus Curiae New Mexico Administrative Hearings Office 1 OPINION

2 ZAMORA, Justice.

3 I. INTRODUCTION

4 {1} The New Mexico Civil Rights Act (CRA), NMSA 1978, §§ 41-4A-1 to -13

5 (2021), authorizes a person to sue a public body for deprivations of the rights,

6 privileges, and immunities guaranteed by the Bill of Rights in Article II, Sections 17

7 and 18 of the New Mexico Constitution. Bradley Bolen (Bolen) asserted a claim

8 under the CRA against the New Mexico Racing Commission (NMRC), alleging that

9 NMRC violated his state constitutional rights by pursuing a vindictive prosecution

10 against him. NMRC moved for summary judgment, arguing that it was entitled to

11 judicial immunity in pursuing an administrative disciplinary proceeding against

12 Bolen. The district court denied NMRC’s motion, concluding that the defense of

13 judicial immunity is unavailable to a public body sued under the CRA. The Court of

14 Appeals reversed, holding both that the defense is available to a public body and that

15 NMRC is entitled to immunity under the facts presented. Bolen v. N.M. Racing

16 Comm’n, 2024-NMCA-056, ¶¶ 12, 20, 553 P.3d 492.

17 {2} We granted certiorari to consider the following question: Is judicial immunity

18 a defense available to a public body sued under the CRA? We answer: Yes, a public

19 body may raise judicial immunity as an affirmative defense to claims brought 1 pursuant to the CRA. We explain that judicial immunity, which applies to judges,

2 advocates, and witnesses, may be consistently applied under the CRA to preserve

3 the role of the judiciary in protecting a person’s constitutional rights. We also

4 articulate a framework for determining when that defense applies to quasi-judicial

5 adjudicatory proceedings in the executive branch. However, as the record and

6 arguments presented here are insufficient to resolve the question of NMRC’s

7 entitlement to immunity, we reverse the Court of Appeals to the extent it held that

8 NMRC is immune from Bolen’s CRA claim. We remand to the district court for

9 further proceedings consistent with this opinion.

10 II. BACKGROUND

11 {3} NMRC is a state administrative agency that regulates New Mexico’s horse

12 racing industry. See NMSA 1978, §§ 60-1A-1 to -30 (2007, as amended through

13 2023). Bolen is a horse trainer licensed by NMRC.

14 {4} In July 2021, Bolen got into an argument with an NMRC racing steward. 1 The

15 disagreement arose when the steward refused to reinstate the license of an assistant

16 trainer whom Bolen wished to employ. The assistant trainer left the room and

1 A racing “‘steward’” is “an employee of [NMRC] who supervises horse races and oversees a race meet while in progress, including holding hearings regarding licensees and enforcing the rule of [NMRC] and the horse racetrack.” Section 60- 1A-2 (GG).

2 1 returned with Bolen on speakerphone, who then argued with the steward about

2 reinstating the trainer. The parties do not dispute that Bolen criticized the steward

3 during the phone call.

4 {5} NMRC initiated an administrative disciplinary action against Bolen, asserting

5 that Bolen transgressed regulations prohibiting “conduct or reputation [which] may

6 adversely reflect on the honesty and integrity of horse racing or interfere with the

7 orderly conduct of a race meeting.” 16.47.1.8(L)(1)(i) NMAC. A panel of three

8 stewards presided over an evidentiary hearing on the asserted infraction, found that

9 Bolen violated 16.47.1.8(L)(1)(i) NMAC, and issued a $500 citation that would be

10 waived and abated so long as Bolen had no additional violations within one year.

11 {6} Bolen appealed the ruling under regulations that entitle him to a de novo

12 hearing before an independent administrative hearing officer. 15.2.1.9(A)(6)(b),

13 (B)(7)(a) NMAC. Bolen also sued NMRC in the district court, asserting a claim

14 under the CRA for a violation of his rights to free speech and due process under

15 Article II, Sections 17 and 18 of the New Mexico Constitution. Bolen alleged that

16 NMRC pursued the disciplinary proceeding in retaliation for his protected speech

17 with the steward and for a previous, unrelated lawsuit he had filed against NMRC’s

18 Executive Director. Bolen ultimately withdrew his administrative appeal, choosing

19 only to pursue litigation in the district court.

3 1 {7} Bolen and NMRC subsequently filed cross-motions for summary judgment.

2 In relevant part, Bolen argued that NMRC violated his constitutional free speech and

3 petition rights by “initiat[ing] . . . a vindictive prosecution in retaliation for his

4 exercise of those rights.” In its motion, NMRC argued that its “quasi-judicial

5 administrative actions” in pursuing the disciplinary proceeding against Bolen entitle

6 it to absolute immunity from Bolen’s CRA claim.

7 {8} The district court refused to extend quasi-judicial immunity to NMRC.

8 Relying on jurisprudence construing the federal civil rights act, 42 U.S.C. § 1983

9 (hereinafter § 1983), the district court reasoned that judicial immunity is based on

10 public policies which “protect[] an individual defendant from personal liability from

11 damages.” The district court decided that these policies were not implicated under

12 the CRA because the enactment only authorizes a plaintiff to sue a public body,

13 which is defined as a governmental entity. See § 41-4A-3(C) (providing that

14 “[c]laims brought pursuant to the [CRA] shall be brought exclusively against a

15 public body”); § 41-4A-2 (defining “public body” to include a list of specified

16 governmental entities). The district court, therefore, concluded that the defense of

17 judicial immunity is unavailable to NMRC.

18 {9} NMRC sought and the Court of Appeals granted an interlocutory appeal. The

19 Court of Appeals held that the district court erred.

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