Anderson, et al. v. New Mexico (Published Opinion)
Annotate this CaseEight named inmates and two nonprofit organizations (collectively, plaintiffs) filed an amended complaint in district court seeking a mixture of a classwide writ of habeas corpus and classwide injunctive and declaratory relief. Plaintiffs alleged that the State’s management of COVID-19 in New Mexico prisons violated inmates’ rights under the New Mexico Constitution. The district court dismissed the amended complaint, concluding that it lacked subject-matter jurisdiction because the individual inmate-plaintiffs failed to exhaust the internal grievance procedures of the New Mexico Corrections Department (NMCD) before seeking relief, as required by NMSA 1978, Section 33-2-11(B) (1990). Agreeing with the result, but not all of its reasoning, the New Mexico Supreme Court affirmed the district court: "to satisfy the habeas corpus exhaustion requirement under Rule 5-802(C) for an entire plaintiff class, one or more named class members must exhaust administrative remedies for each claim. Because no Named Plaintiff exhausted or sought to exhaust NMCD’s internal grievance procedures, we affirm."
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