Jane Doe v. Taos Municipal Schools

CourtDistrict Court, D. New Mexico
DecidedMarch 20, 2025
Docket1:20-cv-01041
StatusUnknown

This text of Jane Doe v. Taos Municipal Schools (Jane Doe v. Taos Municipal Schools) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jane Doe v. Taos Municipal Schools, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

JANE DOE 1,

Plaintiff,

and

JANE DOE 2,

Intervenor-Plaintiff,

v. Case No. 1:20-cv-01041-SCY-JHR

TAOS MUNICIPAL SCHOOLS, LILLIAN TORREZ, ROBERT TRUJILLO, and LISA ABEYTA-VALERIO.

Defendants.

ORDER OVERRULING OBJECTIONS

Plaintiff Jane Doe 1 and Intervenor-Plaintiff Jane Doe 2 were both students at Taos High School who allege they were sexually assaulted by the same fellow student. Jane Doe 1 filed the present case, No. 20cv1041. A few years later, Jane Doe 2 filed a separate case.1 See Doe v. Taos Municipal Schools, 22cv590 KWR/JHR. Magistrate Judge Jerry H. Ritter, the referral Magistrate Judge in both cases, issued a Sanctions Order, finding that Jane Doe 2 violated the Confidentiality Order entered in the present case when Jane Doe 2, who is represented by the same counsel, used information designated as confidential in Jane Doe 1’s case to litigate her case. Doc. 289. Jointly, Plaintiffs Jane Doe 1 and Jane Doe 2 filed an Omnibus Motion in which they sought, among other things, “relief from the Stipulated Confidentiality Order” and reconsideration of the Sanctions Order. Doc. 309. In his Memorandum Opinion and Order on

1 Jane Doe 2 intervened in the present case for the limited purpose of clarifying and amending the Confidentiality Order. Doc. 222. Plaintiffs’ Omnibus Motion for Relief (“Omnibus Order”), Judge Ritter held that Jane Doe 1’s publicly filed versions of her first and second amended complaint are not subject to the Confidentiality Order. Doc. 350. Otherwise, Judge Ritter denied Plaintiffs’ Omnibus Motion. Id. Presently before the Court are Plaintiffs’ objections to that Omnibus Order. Doc. 350. Plaintiffs do not presently object to the sanctions Judge Ritter issued. See Doc. 376 at 12.

Instead, Plaintiffs primarily seek relief from procedures set forth in the operative Confidentiality Order. Plaintiffs, however, have not met their burden to demonstrate that Judge Ritter’s Omnibus Order is clearly erroneous or contrary to law. As such, the Court overrules Plaintiffs’ objections. PROCEDURAL HISTORY 1. Orders, Briefs, and Hearings Leading to the Current Objections On October 22, 2022, Defendants filed a motion for sanctions, arguing that Plaintiff Jane Doe 1 and her counsel violated the Family Educational and Privacy Rights Act (“FERPA”) and the Confidentiality Order entered in this case (Doc. 35) when they shared confidential information with Jane Doe 2. Docs. 207, 210. Jane Doe 2, who is represented by the same

counsel as Jane Doe 1, allegedly then included this confidential information in her separate complaint. Docs. 207, 210. In his “Memorandum Opinion and Order Resolving Jane Doe 2’s Motion to Intervene, [Doc. 182], and Defendants’ Motion for Injunctive Relief and Sanctions, [Docs. 207, 201]” (“Sanctions Order”), Judge Ritter held that Jane Doe 2 and her counsel violated the Confidentiality Order but did not violate FERPA. Doc. 289. As such, Judge Ritter ordered Jane Doe 2’s attorneys to pay Defendants’ attorney’s fees and expenses related to the motion for sanctions and other filings regarding Plaintiffs’ violation of the Confidentiality Order. Id. In response to the Sanctions Order, Plaintiffs filed an “Omnibus Motion for Relief from Stipulated Confidentiality Order [Doc. 35], Reconsideration of September 28 Memorandum Opinion and Order [Doc. 289], and Tolling of the Deadline for Rule 72(a) Objections” (“Omnibus Motion”). Doc. 309. Plaintiffs requested: (1) entry of a superseding confidentiality order; (2) “[a]n order finding that the contents of the publicly filed First and Second Amended

Complaints have been ruled not confidential and may be used and disclosed in Jane Doe 2’s case”; (3) “[a]n order requiring Defendants to produce an itemized log listing all the information and records they wish to designate as confidential, and the specific basis for each such designation”; (4) “[a]n order prohibiting Defendants from designating or redesignating as confidential Plaintiffs’ own records and information within their personal knowledge, or other materials gained through means independent of the court’s processes”; (5) “[r]econsideration of the prospective application of the Court’s [Sanction Order]”; and (6) “[a]cceptance of Plaintiffs’ proposal to satisfy the monetary sanction in the Sanctions Order with a $3,000 direct contribution to a designated Taos charity.” Id. at 27.

While that Omnibus Motion was pending, the Court extended the deadline for Plaintiffs to file Rule 72 objections to the Sanction Order until after the Court resolved the Omnibus Motion. Doc. 344. On September 23, 2024, Judge Ritter issued his Omnibus Order, largely denying the Omnibus Motion. Doc. 350. Specifically, he: (1) declined to consider arguments regarding a superseding confidentiality order that Plaintiffs attempted to incorporate by reference, finding that Plaintiffs attempt to do so violated the Local Rules on page limits; (2) held that the publicly filed versions of Jane Doe 1’s pleading are not subject to the Confidentiality Order, but that the Confidentiality Order does protect the underlying confidential materials upon which the pleadings rely or incorporate; (3) declined to require Defendants to produce a log of all information they designated as confidential because (a) there was inadequate grounds to sanction Defendants based on their assertions of confidentiality, and (b) the Confidentiality Order provides a mechanism for challenging Defendants’ confidentiality designations and Plaintiffs did not invoke it; (4) declined to issue a blanket order regarding the confidentiality of public information because the Confidentiality Order in this case already

provides that publicly available information cannot be made confidential; (5) denied Plaintiffs’ request to reconsider the sanctions previously imposed; and (6) denied Plaintiffs’ request to make a charitable donation instead of paying Defendants’ attorney’s fees. Id. Thereafter, Plaintiffs did not file Rule 72 objections to the underlying Sanctions Order. Instead, Plaintiffs filed objections to portions of the Omnibus Order. Doc. 364; see also Doc. 374 (response); Doc. 376 (reply). 2. History of the Confidentiality Order One month after the initial scheduling conference in this case, the Court entered a Stipulated Protective and Confidentiality Order, providing that information marked as confidential be “protected from disclosure outside this litigation.”2 Doc. 31; Doc. 35 at 1. Over a

year after the Court entered the Confidentiality Order, Jane Doe 2 moved to intervene in the present case for the limited purpose of clarifying and amending the Confidentiality Order so that she could access information marked confidential in the Jane Doe 1 case. Doc. 182. Around the same time, Defendants moved for sanctions, asserting that Jane Doe 1 violated the confidentiality order by sharing confidential information with Jane Doe 2. Docs. 207, 210. In the September 28, 2023 Sanctions Order, Judge Ritter held that amending the Confidentiality Order

2 The Court later amended the Confidentiality Order twice to add additional categories of information to the definition of “Confidential Information,” but the other terms of the Confidentiality Order stayed the same. Docs. 59, 61. was not yet appropriate because the parties “seem to strongly disagree on the issue of amendment, but discussions and briefs have been overwhelmed by the issue of sanctions.” Doc. 289 at 28.

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Jane Doe v. Taos Municipal Schools, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jane-doe-v-taos-municipal-schools-nmd-2025.