Aztec Municipal Schools v. Cardenas

Ana Cardenas (plaintiff) permanently injured her knee while working as a special-education teacher for Aztec Municipal Schools (Aztec) (defendant). The incident also caused Cardenas to suffer a secondary mental impairment. Cardenas applied for workers’ compensation for both impairments. For the primary knee injury, an administrative judge awarded Cardenas permanent partial disability benefits for 150 weeks. If Cardenas had suffered a secondary physical impairment, her benefits award for that additional impairment could have been up to 500 weeks. However, because Cardenas’s secondary impairment was mental and not physical, the law restricted her benefits award for that secondary issue to the award length for her primary impairment, or 150 weeks. Accordingly, the administrative judge awarded Cardenas only 150 weeks of benefits for her secondary mental impairment. Cardenas appealed the decision to the New Mexico Court of Appeals, alleging that (1) the workers’-compensation law treated people with secondary mental impairments differently from people with secondary physical impairments and (2) this differential treatment meant the law violated the Equal Protection Clause in the New Mexico Constitution. Aztec argued that the differential treatment was necessary to save costs for the workers’-compensation program. The appellate court ruled that the law was unconstitutional. The New Mexico Supreme Court agreed to review the matter.