Riley v. Jordan

CourtDistrict Court, D. New Mexico
DecidedMay 8, 2025
Docket1:25-cv-00044
StatusUnknown

This text of Riley v. Jordan (Riley v. Jordan) 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
Riley v. Jordan, (D.N.M. 2025).

Opinion

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

SHANNON S. RILEY,

Plaintiff, vs. No. 1:25-cv-00044-KWR-KK

HEATHER JORDAN in her individual and official capacities as the Director of the New Mexico Workers' Compensation Administration,

Defendant.

MEMORANDUM ORDER AND OPINION GRANTING PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION

THIS MATTER comes before the Court based on Plaintiff’s Motion for Preliminary Injunction and the associated briefing (doc. 2; doc. 8, doc. 10). Having considered the parties’ briefing and applicable law, finds that Plaintiff’s Motion is well taken and is therefore GRANTED. BACKGROUND

Plaintiff served as a Workers’ Compensation Judge (WCJ) for the New Mexico Worker’s Compensation Administration (WCA) from her appointment on August 20, 2011, to her termination on November 13, 2024. Doc. 2 at 1–2. This action arises from the events leading to her termination, beginning on November 5, 2024. Id. On Election Day, November 5, 2024, Plaintiff submitted a pre-approval request for two hours of administrative leave for the purpose of voting. Id. at 2. While she arrived at the polls, Plaintiff ultimately did not vote because there was a line and because she was sick. Id. Plaintiff was aware that she needed to make corrections to her timesheet and intended to make the corrections. the following morning on November 7, 2024. Id. Prior to the commencement of this action, Plaintiff had over 200 hours of annual leave and over 240 hours of sick leave, which she could have substituted, or alleges that she alternatively could have removed the two hours of as she had already worked a significant number of hours that day. Id. The WCA office was closed on November 7 due to inclement weather, and Plaintiff did not have access to her laptop. Id. She alleges that as a result of these events, she “simply forgot to edit her timesheet.” Id. On November 12, 2024, Governor Michelle Lujan Grisham appointed Defendant Heather

Jordan as the new Director of the WCA. Id. Defendant fired Plaintiff on November 13, 2024, alleging that she had committed time fraud and had thus violated the Code of Judicial Conduct by entering two hours of voting leave into her timesheet and failing to vote. According to the letter, “[s]uch conduct is a violation of the code of judicial conduct, which requires you to promote integrity and to ‘avoid impropriety and the appearance of impropriety.’” Id. Plaintiff filed suit on January 14, 2024, seeking injunctive relief and damages under 42 U.S.C. §1983 for civil rights violations, including being deprived of her property interest in her employment without due process of law. Doc. 1. At the time of the initial lawsuit, Defendant had not submitted a complaint about the events to the State Personnel board. Doc. 7 at 2. On February

4, 2025, the Workers’ Compensation Administration subsequently submitted a complaint to the State Personnel Board, in accordance with Section 52-5-2(C) and New Mexico Administrative Code, 1.7.12.25. Id. On March 4, 2025, the Board granted Plaintiff’s motion and filed an Order of Dismissal dismissing the WCA’s complaint for lack of jurisdiction. Doc. 14-1. Defendant offered Plaintiff a modified form of reinstatement on February 6, 2025. Doc. 7-2. The offer involved being reinstated to her former position as a Workers’ Compensation Judge and placed on paid administrative leave pending the outcome of the State Personnel Board proceedings. Id. It also departed from Plaintiff’s original employment in that it made her an at- will employee serving at the pleasure of the Governor, rather than subject to firing only for violations of the judicial code of conduct. Id.; doc. 10 at 2. Plaintiff rejected the modified offer on February 14, 2025. Doc. 10-1. Plaintiff asserted that it varied substantively from her original employment and that its restrictions on communication violated her First Amendment right to freedom of speech. Defendant gave Plaintiff an updated offer of reinstatement on February 26, 2025, that

would still place her on administrative leave until the completion of proceedings but changed the at-will employee language to render Plaintiff able to be fired only in cases of violations of the code of judicial misconduct. Doc. 18-1. Plaintiff rejected the offer on the grounds that it continued to violate her First Amendment right to freedom of speech and still did not restore the status quo. Doc. 18-2. Defendant now contends that Plaintiff’s second rejection renders her responsible for her ongoing unemployment and moots her cause of action. Doc. 15 at 1. Plaintiff maintains that she is entitled to a preliminary injunction and that the Court should not grant Defendant’s motion to dismiss. Doc. 12 at 1. LEGAL STANDARD

“A preliminary injunction is an extraordinary remedy, the exception rather than the rule.” Mrs. Fields Franchising, LLC v. MFGPC, 941 F.3d 1221, 1232 (10th Cir. 2019) (quoting Free the Nipple–Fort Collins v. City of Fort Collins, Colo., 916 F.3d 792, 797 (10th Cir. 2019)). “[B]ecause a preliminary injunction is an extraordinary remedy, the movant's right to relief must be clear and unequivocal.” Fundamentalist Church of Jesus Christ of Latter–Day Saints v. Horne, 698 F.3d 1295, 1301 (10th Cir.2012) (citations omitted). To obtain a preliminary injunction, Plaintiff must show: “(1) a substantial likelihood of prevailing on the merits; (2) irreparable harm unless the injunction is issued; (3) that the threatened injury outweighs the harm that the preliminary injunction may cause the opposing party; and (4) that the injunction, if issued, will not adversely affect the public interest.” Dine Citizens Against Ruining Our Env't v. Jewell, 839 F.3d 1276, 1281 (10th Cir. 2016) (quoting Davis v. Mineta, 302 F.3d 1104, 1111 (10th Cir. 2002)). Courts disfavor preliminary injunctions that “exhibit any of three characteristics: (1) it mandates action (rather than prohibiting it), (2) it changes the status quo, or (3) it grants all the

relief that the moving party could expect from a trial win.” Mrs. Fields Franchising, LLC, 941 F.3d at 1232 (quoting Free the Nipple-Fort Collins, 916 F.3d at 797). Because Plaintiff’s request mandates action, she faces “a heavier burden on the likelihood-of-success-on-the-merits and the balance-of-harms factors.” Id. ANALYSIS Plaintiff has demonstrated that she is entitled to a preliminary injunction, even when considering the higher burden she must bear in seeking an affirmative injunction. Courts disfavor preliminary injunctions that (1) mandate action (rather than prohibiting it), (2) change the status quo, or (3) grant all the relief that the moving party could expect from a trial

win.” Mrs. Fields Franchising, LLC, 941 F.3d at 1232 (quoting Free the Nipple-Fort Collins, 916 F.3d at 797). The Supreme Court has affirmatively stated that purpose of a preliminary injunction is “to preserve the relative positions of the parties until a trial on the merits can be held.” Univ. of Tex. v. Camenisch, 451 U.S. 390, 395 (1981). The goal is to preserve the status quo until the Court can more completely resolve the issue on its merits. Id. To determine the status quo, the Court looks to the “last peaceable uncontested status existing between the parties before the dispute developed[.]” Schrier v. Univ. of Colo., 427 F.3d 1253, 1260 (10th Cir. 2005) (quoting 11A Charles Alan Wright et al., Federal Practice and Procedure § 2948, at 136 (2d ed.1995)).

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Riley v. Jordan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/riley-v-jordan-nmd-2025.