Patrick Burke v. Lea County Board of County Commissioners and Corey Helton

District Court, D. New Mexico·Decided July 27, 2026·No. 2:24-cv-00601·Unknown

Opinion

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

PATRICK BURKE,

Plaintiff,

v. No. 2:24-cv-00601-JHR-GBW

LEA COUNTY BOARD OF COUNTY COMMISSIONERS and COREY HELTON,

Defendants.

MEMORANDUM OPINION AND ORDER GRANTING DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT [DOC. 59] THIS MATTER comes before the Court on Defendants Corey Helton and the Lea County Board of County Commissioners’ Motion for Summary Judgment. [Doc. 59]. Plaintiff Patrick Burke filed a response [Doc. 62] and Defendants replied [Doc. 64]. The Court, having reviewed the briefing, case record, and applicable law, finds the motion well taken and GRANTS summary judgment in favor of Defendants. I. PROCEDURAL BACKGROUND Burke filed suit on June 13, 2024, alleging that Sheriff Helton and the Lea County Sheriff’s Office (“LCSO”) blackballed Burke for a year from law enforcement and security work in and around Lea County. [Doc. 1]. The suit’s claims included: violation of the New Mexico Civil Rights Act (“NMCRA”) against Lea County; violation of the New Mexico Tort Claims Act (“NMTCA”) against Helton; and a 42 U.S.C. § 1983 claim against Helton for violation of his right to interstate travel. Id. at 5–6. Defendants filed a motion to dismiss Burke’s NMCRA and § 1983 claims on July 25, 2024. [Doc. 10]. The Court granted the motion in part, dismissing the § 1983 claim.1 The parties proceeded to discovery, which closed on November 16, 2025. [Doc. 28, at 2]. On December 16, 2025, Defendants filed their summary judgment motion against Burke’s remaining claims. [Doc. 59]. II. THE PARTIES’ UNDISPUTED AND DISPUTED FACTS

A. The Parties’ Undisputed Facts. The parties do not dispute the following facts. [Doc. 59, at 2–5]; [Doc. 62, at 3–8]; [Doc. 64, at 2–7]. From April 2015 until his resignation on August 4, 2021, Burke worked as an officer for the LCSO. Prior to resigning, Burke did not report for duty on July 30th, July 31st, and August 1st. Burke had also received a job offer to work for the U.S. Department of Army Civilian Police in Hohenfels, Germany. On August 3, 2021, Chief Deputy Chan Kim traveled to Burke’s home in Gaines County, Texas to meet with him. Burke resigned from the LCSO the next day and began working for the Army Police in

September 2021. Approximately six weeks later, Burke’s supervisor and an unidentified official told him the Army Police’s Provost Marshall received an anonymous call from someone claiming Burke never worked for the LCSO nor received law enforcement certification.2 Burke continued to work with the Army Police until May 2022. Burke attributes his decision to leave to how his

1 Burke brought suit on the basis of federal question jurisdiction. [Doc. 1, at 2]. Although the Court has dismissed the federal claim, it retains subject matter jurisdiction under 28 U.S.C. § 1332 given the complete diversity of citizenship between the parties and the amount in controversy. 2 Burke asserts the caller identified himself as a former co-worker, but Defendants do not stipulate to this fact. While Defendants do not stipulate that Burke’s supervisors approached him about this call for purposes of trial, they will not dispute it “for purposes of [this motion] only.” [Doc. 59, at 3]. supervisors limited him to desk duty and “made [his] day-to-day work life miserable” after the anonymous call. [Doc. 62-3, at 3]. Burke and his family returned to Texas, and between May and October 2022 Burke applied for law enforcement and security positions with the City of Hobbs Police Department (“Hobbs PD”), the City of Lovington Police Department (“Lovington PD”), the City of Carlsbad Police

Department (“Carlsbad PD”), and Great Plains Analytical Services (“GAS”), Inc., a private oil and gas company, among others. Hobbs PD, Lovington PD, and GAS, Inc. did not hire Burke, but Carlsbad PD did. Burke left Carlsbad PD due to the commute and scheduling challenges and took a job at the Waste Isolation Pilot Plant, a U.S. Department of Energy nuclear waste disposal site. In October 2023, Burke and his wife encountered Helton at a Home Depot in Lea County. The parties had a tense interaction before going their separate ways. B. The Parties’ Disputed Facts. The parties dispute the following facts. See [Doc. 59 at 2–5]; [Doc. 62, at 3–8]; [Doc. 64, at 2–7].

First, the parties dispute what happened during and after Kim’s visit to Burke’s home on August 3, 2021. Burke claims that he properly requested leave to deal with recurring migraines from July 30th to August 1st. Kim appeared unannounced in his full uniform, placed his hand on his gun, closed the distance between them, and berated Burke for “disloyalty.” Burke also claims that he called Helton after Kim left, and Helton admitted to sending Kim while screaming at him for leaving the LCSO. Burke alleges that Chief Deputy Fernando Jimenez called him later the same evening to tell him not to report for duty and inform him an internal affairs investigation into Burke had begun. Burke decided to resign immediately, driving to the LCSO the next day to turn in his cruiser, gear, and credentials. While there, Burke alleges that Undersheriff Michael Walker informed him the LCSO would still suspend, terminate, and investigate him despite his resignation. Defendants claim Kim only spoke to Burke about his absences, which Defendants assert were unapproved, and other “work-related concerns.” Kim testified in his deposition that Burke told him he suffered from Post-Traumatic Stress Disorder. Upon learning this information Walker decided to put Burke on administrative leave before Burke resigned and left for the Army Police.

Defendants deny any of Burke’s alleged conversations with Helton or Walker occurred and deny that the LCSO initiated an internal affairs investigation into Burke. Second, the parties dispute whether Helton and the LCSO misled or otherwise pressured Hobbs PD, Lovington PD, Carlsbad PD, or GAS, Inc. to deny Burke employment. Burke asserts that after progressing far in the hiring process, each potential employer except Carlsbad PD suddenly rejected his application. Burke alleges he then learned from people inside the police departments and GAS, Inc. that Helton and his deputies had lied about Burke’s prior job performance or threatened retaliation against them if they hired Burke. Burke also alleges that Helton drove his cruiser past him several times in Lea County to intimidate him while he worked

in a friend’s yard. Defendants deny Helton drove by Burke and deny that Helton or any other LCSO officer threatened, influenced, or otherwise attempted to persuade these potential employers to reject Burke. Third, the parties dispute what occurred at Home Depot in October 2023. [Doc. 62-3, at 4]; [Doc. 59, at 53]. Burke claims that Helton approached him and demanded to know why Burke was in Lea County. When Burke chuckled, Helton stated, “you remember who I am and what I am right?” while tapping his sheriff’s badge. When Burke’s wife joined them, she became upset with Helton. Helton mocked Burke for his employment struggles and told him he should have stayed “loyal” to the LCSO. Burke told his wife that a fight would not be worth it, and the two left. Helton denies he made any of these statements. Helton instead claims that he saw Burke at the Home Depot and greeted him. Burke responded by making “a dismissive ‘pfft’ sound,” to which Helton responded “alrighty then” and started walking away. Burke’s wife then joined the two and “accused [Helton] of being disrespectful,” and Helton “voluntarily walked away from that interaction.”

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Patrick Burke v. Lea County Board of County Commissioners and Corey Helton, (D.N.M. 2026).

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