New Mexico Supreme Court ruled Monday that state racing authorities can claim judicial immunity in civil rights lawsuits when performing administrative actions that are judicial in nature, stemming from a 2021 dispute between a trainer and racing officials.
The case originated when trainer Bradley Bolen engaged in a heated telephone conversation with a state steward from the New Mexico Racing Commission (NMRC) over licensing issues concerning an assistant trainer Bolen wished to employ.
Following the call, racing officials determined Bolen had violated regulations prohibiting conduct that “may adversely reflect on the honesty and integrity of horse racing.” A three-steward panel imposed a $500 fine that would be waived if Bolen maintained compliance for one year.
Bolen initially appealed the ruling through administrative channels but later abandoned that process in favor of filing a lawsuit under New Mexico’s Civil Rights Act (CRA). His complaint alleged the disciplinary action represented retaliation for protected speech and referenced a previous, unrelated lawsuit he had filed against NMRC’s Executive Director.
The NMRC sought dismissal, arguing its “quasi-judicial administrative actions” entitled it to absolute immunity from Bolen’s claims.
“Judicial immunity is justified by public policies supporting independent decision-making and ensuring the integrity of a judicial or quasi-judicial process,” the Supreme Court wrote in its opinion. “These policies apply to both individuals and governmental entities performing judicial functions.”
While establishing that judicial immunity can serve as a defense for governmental bodies in civil rights cases, the court stopped short of determining whether immunity specifically applied in Bolen’s situation.
Instead, the Supreme Court remanded the case to district court, instructing it to “determine whether and to what extent NMRC is immune using the framework set forth in this opinion.”
The ruling emphasizes that judicial immunity should be narrowly applied, protecting only genuine judicial functions.
“A court considering a public body’s entitlement to judicial immunity should carefully parse the challenged conduct to determine whether and to what extent that conduct consists of a judicial function,” the opinion stated. “Judicial immunity will protect a public body from liability only when the nature of the proceeding and the nature of the challenged conduct merit absolute protection from suit.”
The decision comes nearly four years after the original telephone dispute that triggered the legal battle, establishing an important precedent for how New Mexico’s governmental organizations may defend themselves in civil rights litigation.
