Nava v. City of Santa Fe

Summary

The Supreme Court of New Mexico affirmed a judgment for Deanna Nava on her New Mexico Human Rights Act hostile work environment sexual-harassment claim against the City of Santa Fe. The court held that a mixed-motive jury instruction was proper and that substantial evidence supported findings that the harassment was based on sex and sufficiently severe or pervasive. It also upheld remittitur of damages, denial of post-judgment interest against the municipality, and the district court's attorney-fee award.

Holdings

1. The mixed-motive instruction was not erroneous because a plaintiff need only establish that sex was a motivating factor in the challenged employment treatment; sex need not be the sole or primary motivation.
2. Substantial evidence supported the jury's finding that Gallegos's harassment of Nava was because of her sex.
3. Substantial evidence supported the jury's finding that the harassment was sufficiently severe or pervasive to alter the terms and conditions of Nava's employment.
4. The district court properly ordered remittitur because the $285,000 jury award was unsupported by the evidence and plainly manifested passion or prejudice rather than reason or justice.
5. Nava was not entitled to post-judgment interest because the NMHRA did not expressly waive the State's immunity from post-judgment interest.
6. The district court did not abuse its discretion by awarding attorney's fees based on a $200 hourly rate rather than the requested $230 rate.

Questions Presented

1. Whether the district court's mixed-motive jury instruction improperly permitted the jury to find liability if sex was merely a motivating factor rather than the sole or primary cause of the harassment.
2. Whether substantial evidence supported the jury's findings that the harassment occurred because of Nava's sex and was sufficiently severe or pervasive to create a hostile work environment.
3. Whether the district court properly ordered remittitur of the jury's $285,000 damages award to $90,250.
4. Whether Nava was entitled to post-judgment interest against the City under the New Mexico Human Rights Act.
5. Whether the district court abused its discretion by setting Nava's statutory attorney's fees using a $200 hourly rate rather than the requested $230 rate.

Disposition

affirmed