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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW MEXICO
CHARLES CHED MACQUIGG,
Plaintiff,
v. Cause No. 1:12-cv-01137 CG-WDS
The ALBUQUERQUE PUBLIC
SCHOOLS BOARD OF EDUCATION,MARTIN ESQUIVEL, in his
individual
capacity, DAVID ROBBINS, in his
individual capacity, WINSTON
BROOKS, in his individual capacity,
STEVE TELLEZ, in his individualcapacity, MONICA ARMENTA, in
her
individual capacity, RIGO CHAVEZ, RecordsCustodian,
Defendants.
CERTAIN DEFENDANTS ANSWER TO VERIFIED COMPLAINT FOR
VIOLATIONS OF THE FIRST AND FOURTEENTH AMENDMENTS
TO THE UNITED STATES CONSTITUTION AND TO ENFORCE
THE NEW MEXICO INSPECTION OF PUBLIC RECORDS ACT
COME NOW Defendants The Albuquerque Public Schools Board of
Education, David
Robbins, Winston Brooks, Steve Tellez, Monica Armenta and Rigo
Chavez, by and through their
attorneys, Yenson, Allen & Wosick, P.C., and for their
Answer to Plaintiffs Verified
Complaint for Violations of the First and Fourteenth Amendments
to the United States
Constitution and to Enforce the New Mexico Inspection of Public
Records Act, state as follows.
I. GENERAL NATURE OF THE ALLEGATIONS
Background related to the First Amendment Claims
1. These Defendants deny the allegations contained in Paragraph
1 of Plaintiffs
Complaint.
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2. These Defendants admit Plaintiff is a retired APS teacher.
These Defendants are
without knowledge or information sufficient to form a belief as
to the remaining allegations
contained in Paragraph 2 of Plaintiffs Complaint.
3. These Defendants deny all portions of APS Board meetings are
open to the public
and include time for public comment, and deny that APS Board
meetings are designated public
forums under the First Amendment. These Defendants admit the
remaining allegations
contained in Paragraph 3 of Plaintiffs Complaint.
4. These Defendants admit Plaintiff has frequently attended
School Board meetings,
but are without sufficient information to admit or deny the
remaining allegations contained in
Paragraph 4 of Plaintiffs Complaint.
5. These Defendants deny Plaintiff writes original news stories.
These Defendants
admit the remaining allegations contained in Paragraph 5 of
Plaintiffs Complaint.
6. These Defendants deny the allegations contained in Paragraph
6 of Plaintiffs
Complaint.
7. These Defendants deny the allegations contained in Paragraph
7 of Plaintiffs
Complaint.
8. These Defendants deny the allegations contained in Paragraph
8 of Plaintiffs
Complaint.
Background related to the Inspection of Public Records Act
Claim
9. These Defendants deny the allegations contained in Paragraph
9 of Plaintiffs
Complaint.
10. Paragraph 10 of Plaintiffs Complaint states a legal
conclusion and requires no
response.
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11. Paragraph 11 of Plaintiffs Complaint states a legal
conclusion and requires no
response.
12. These Defendants admit the allegations contained in
Paragraph 12 of Plaintiffs
Complaint.
13. These Defendants deny the allegations contained in Paragraph
13 of Plaintiffs
Complaint.
14. These Defendants deny the allegations contained in Paragraph
14 of Plaintiffs
Complaint.
II. JURISDICTION AND VENUE
15. These Defendants admit the allegations contained in
Paragraph 15 of Plaintiffs
Complaint.
16. These Defendants admit the allegations contained in
Paragraph 16 of Plaintiffs
Complaint.
III. PARTIES
17. These Defendants are without knowledge or information
sufficient to form a
belief as to the allegations contained in Paragraph 17 of
Plaintiffs Complaint.
18. Paragraph 18 of Plaintiffs Complaint states a legal
conclusion and requires no
response. To the extent Paragraph 18 purports to allege facts,
these Defendants deny those
allegations.
19. These Defendants admit the allegations contained in
Paragraph 19 of Plaintiffs
Complaint.
20. These Defendants admit the allegations contained in
Paragraph 20 of Plaintiffs
Complaint.
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30. These Defendants are without knowledge or information
sufficient to form a
belief as to the allegations contained in Paragraph 30 of
Plaintiffs Complaint.
31. These Defendants are without knowledge or information
sufficient to form a
belief as to the allegations contained in Paragraph 31 of
Plaintiffs Complaint.
32. These Defendants admit Plaintiff began attending APS
meetings after his
retirement. These Defendants are without knowledge or
information sufficient to form a belief
as to the remaining allegations contained in Paragraph 32 of
Plaintiffs Complaint.
33. These Defendants deny Plaintiffs blog is news-oriented.
These Defendants are
without knowledge or information sufficient to form a belief as
to the remaining allegations
contained in Paragraph 33 of Plaintiffs Complaint (although to
the extent the quoted language
from Plaintiffs blog purports to allege facts, those facts are
denied).
34. These Defendants are without knowledge or information
sufficient to form a
belief as to the allegations contained in Paragraph 34 of
Plaintiffs Complaint (although to the
extent the quoted language from Plaintiffs blog purports to
allege facts, those facts are denied).
35. These Defendants deny the allegations contained in Paragraph
35 of Plaintiffs
Complaint.
36. These Defendants admit Plaintiff frequently attended APS
Board meetings.
These Defendants deny the remaining allegations contained in
Paragraph 36 of Plaintiffs
Complaint.
37. These Defendants are without knowledge or information
sufficient to form a
belief as to the allegations contained in Paragraph 37 of
Plaintiffs Complaint.
38. These Defendants deny the allegations contained in Paragraph
38 of Plaintiffs
Complaint.
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39. These Defendants deny the allegations contained in Paragraph
39 of Plaintiffs
Complaint.
40. These Defendants deny the allegations contained in Paragraph
40 of Plaintiffs
Complaint.
The November 4, 2009, Regular APS Board Meeting
41. These Defendants deny the allegations contained in Paragraph
41 of Plaintiffs
Complaint.
42. These Defendants admit the allegations contained in
Paragraph 42 of Plaintiffs
Complaint.
43. These Defendants admit the allegations contained in
Paragraph 43 of Plaintiffs
Complaint.
44. These Defendants are without knowledge or information
sufficient to form a
belief as to the allegations contained in Paragraph 44 of
Plaintiffs Complaint.
45. These Defendants deny the allegations contained in Paragraph
45 of Plaintiffs
Complaint.
46. These Defendants deny the allegations contained in Paragraph
46 of Plaintiffs
Complaint.
47. These Defendants admit the quoted portion of Paragraph 47 of
Plaintiffs
Complaint reflects some, but not all, of the referenced
interaction.
48. These Defendants deny the allegations contained in Paragraph
48 of Plaintiffs
Complaint.
49. These Defendants deny the allegations contained in Paragraph
49 of Plaintiffs
Complaint.
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The August 19, 2010, Gubernatorial Debate at El Dorado High
School
50. These Defendants admit the debate took place on August 19,
2012 at Eldorado
High School. These Defendants deny the remaining allegations
contained in Paragraph 50 of
Plaintiffs Complaint.
51. These Defendants deny the allegations contained in Paragraph
51 of Plaintiffs
Complaint.
52. These Defendants deny Plaintiff is a member of the press.
These Defendants
are without knowledge or information sufficient to form a belief
as to the remaining allegations
contained in Paragraph 52 of Plaintiffs Complaint.
53. These Defendants admit the allegations contained in
Paragraph 53 of Plaintiffs
Complaint.
54. These Defendants deny the allegations contained in Paragraph
54 of Plaintiffs
Complaint.
55. These Defendants deny the allegations contained in Paragraph
55 of Plaintiffs
Complaint.
56. These Defendants deny the allegations contained in Paragraph
56 of Plaintiffs
Complaint.
57. These Defendants deny the allegations contained in Paragraph
57 of Plaintiffs
Complaint.
58. These Defendants are without knowledge or information
sufficient to form a
belief as to the allegations contained in Paragraph 58 of
Plaintiffs Complaint.
59. These Defendants are without knowledge or information
sufficient to form a
belief as to the allegations contained in Paragraph 59 of
Plaintiffs Complaint.
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60. These Defendants deny the allegations contained in Paragraph
60 of Plaintiffs
Complaint.
61. These Defendants admit the quoted portion of Paragraph 61 of
Plaintiffs
Complaint reflects some, but not all, of the referenced
interaction.
62. These Defendants deny the allegations contained in Paragraph
62 of Plaintiffs
Complaint.
63. These Defendants deny the allegations contained in Paragraph
63 of Plaintiffs
Complaint.
The August 25, 2010, Audit Committee Meeting
64. These Defendants deny Plaintiffs rights were violated. These
Defendants admit
the remaining allegations contained in Paragraph 64 of
Plaintiffs Complaint.
65. These Defendants deny Plaintiffs rights were violated. These
Defendants admit
the remaining allegations contained in Paragraph 65 of
Plaintiffs Complaint.
66. These Defendants deny that all portions of Audit Committee
meetings are open to
the public. These Defendants admit the remaining allegations
contained in Paragraph 66 of
Plaintiffs Complaint.
67. These Defendants admit Plaintiff attended the August 25,
2010, meeting. These
Defendants are without knowledge or information sufficient to
form a belief as to the remaining
allegations contained in Paragraph 67 of Plaintiffs
Complaint.
68. These Defendants admit the allegations contained in
Paragraph 68 of Plaintiffs
Complaint.
69. These Defendants admit the allegations contained in
Paragraph 69 of Plaintiffs
Complaint.
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70. These Defendants deny the allegations contained in Paragraph
70 of Plaintiffs
Complaint.
71. These Defendants admit the allegations contained in
Paragraph 71 of Plaintiffs
Complaint.
72. These Defendants deny the allegations contained in Paragraph
72 of Plaintiffs
Complaint.
73. These Defendants deny the allegations contained in Paragraph
73 of Plaintiffs
Complaint.
74. These Defendants deny the allegations contained in Paragraph
74 of Plaintiffs
Complaint.
75. These Defendants admit the quoted portion of Paragraph 75 of
Plaintiffs
Complaint reflects some, but not all, of the referenced
interaction.
76. These Defendants admit the allegations contained in
Paragraph 76 of Plaintiffs
Complaint.
77. These Defendants deny the allegations contained in Paragraph
77 of Plaintiffs
Complaint.
78. These Defendants deny the allegations contained in Paragraph
78 of Plaintiffs
Complaint.
The September 1, 2010, Banning Order
79. These Defendants deny Paragraph 79 of Plaintiffs Complaint
accurately or fully
states the content of the letter attached as Ex. D.
80. These Defendants admit the allegations contained in
Paragraph 80 of Plaintiffs
Complaint.
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81. These Defendants deny the allegations contained in Paragraph
81 of Plaintiffs
Complaint.
82. These Defendants deny the allegations contained in Paragraph
82 of Plaintiffs
Complaint.
83. These Defendants deny the allegations contained in Paragraph
83 of Plaintiffs
Complaint.
84. These Defendants deny Paragraph 84 of Plaintiffs Complaint
accurately or fully
reflects the contents of the letter attached as Ex. D.
85. These Defendants deny the allegations contained in Paragraph
85 of Plaintiffs
Complaint.
86. These Defendants deny Paragraph 86 of Plaintiffs Complaint
accurately or fully
reflects the contents of the letter attached as Ex. D.
87. These Defendants deny the allegations contained in Paragraph
87 of Plaintiffs
Complaint.
88. These Defendants deny the allegations contained in Paragraph
88 of Plaintiffs
Complaint.
89. These Defendants admit the allegations contained in
Paragraph 89 of Plaintiffs
Complaint.
90. These Defendants deny the allegations contained in Paragraph
90 of Plaintiffs
Complaint.
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91. These Defendants deny the allegations contained in Paragraph
91 of Plaintiffs
Complaint.
The Request for Records under the New Mexico Inspection of
Public Records Act, NMSA1978, 14-2-1 et seq.
92. These Defendants admit the allegations contained in
Paragraph 92 of Plaintiffs
Complaint.
93. These Defendants admit the allegations contained in
Paragraph 93 of Plaintiffs
Complaint.
94. These Defendants deny the allegations contained in Paragraph
94 of Plaintiffs
Complaint.
95. These Defendants admit the allegations contained in
Paragraph 95 of Plaintiffs
Complaint.
96. These Defendants deny Paragraph 96 of Plaintiffs Complaint
accurately or fully
reflects the contents of the letter attached as Ex. F.
97. These Defendants admit the allegations contained in
Paragraph 97 of Plaintiffs
Complaint.
98. These Defendants admit the allegations contained in
Paragraph 98 of Plaintiffs
Complaint.
99. These Defendants deny Paragraph 99 of Plaintiffs Complaint
accurately or fully
reflects the contents of the letter attached as Ex. H.
100. These Defendants deny Paragraph 100 of Plaintiffs Complaint
accurately or fully
reflects the contents of the letter attached as Ex. I.
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V. CLAIMS
FEDERAL LAW CLAIMS
COUNT ICLAIM UNDER 42 U.S.C. 1983 FOR VIOLATION OF
PLAINTIFFSFIRST AMENDMENT RIGHT TO FREEDOM OF SPEECHPRIOR
RESTRAINT
101. These Defendants incorporate by reference as though fully
set forth herein, their
answers to the allegations contained in Paragraphs 1 through 100
of Plaintiffs Complaint.
102. These Defendants admit the allegations contained in
Paragraph 102 of Plaintiffs
Complaint.
103. Paragraph 103 ofPlaintiffs Complaint states a legal
conclusion and requires no
response. To the extent Paragraph 103 purports to allege facts,
these Defendants deny those
allegations.
104. Paragraph 104 of Plaintiffs Complaint states a legal
conclusion and requires no
response. To the extent Paragraph 104 purports to allege facts,
these Defendants deny those
allegations.
105. These Defendants deny the allegations contained in
Paragraph 105 of Plaintiffs
Complaint.
106. These Defendants deny the allegations contained in
Paragraph 106 of Plaintiffs
Complaint.
107. These Defendants deny the allegations contained in
Paragraph 107 of Plaintiffs
Complaint.
108. These Defendants deny the allegations contained in
Paragraph 108 of Plaintiffs
Complaint.
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COUNT IIICLAIM UNDER 42 U.S.C. 1983 FOR VIOLATION OF
PLAINTIFFS
FIRST AMENDMENT RIGHT TO FREEDOM OF SPEECHRETALIATION
118. These Defendants incorporate by reference as though fully
set forth herein, their
answers to the allegations contained in Paragraphs 1 through 117
of Plaintiffs Complaint.
119. These Defendants admit the allegations contained in
Paragraph 119 of Plaintiffs
Complaint.
120. Paragraph 120 ofPlaintiffs Complaint states a legal
conclusion and requires no
response. To the extent Paragraph 120 purports to allege facts,
these Defendants deny those
allegations.
121. Paragraph 121 ofPlaintiffs Complaint states a legal
conclusion and requires no
response. To the extent Paragraph 121 purports to allege facts,
these Defendants deny those
allegations.
122. These Defendants deny the allegations contained in
Paragraph 122 of Plaintiffs
Complaint.
123. These Defendants deny the allegations contained in
Paragraph 123 of Plaintiffs
Complaint.
124. These Defendants deny the allegations contained in
Paragraph 124 of Plaintiffs
Complaint.
COUNT IVCLAIM UNDER 42 U.S.C. 1983 FOR VIOLATION OF
PLAINTIFFS
FOURTEENTH AMENDMENT RIGHT TO DUE PROCESS
125. These Defendants incorporate by reference as though fully
set forth herein, their
answers to the allegations contained in Paragraphs 1 through 124
of Plaintiffs Complaint.
126. These Defendants admit the allegations contained in
Paragraph 126 of Plaintiffs
Complaint.
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127. Paragraph 127 ofPlaintiffs Complaint states a legal
conclusion and requires no
response. To the extent Paragraph 127 purports to allege facts,
these Defendants deny those
allegations.
128. Paragraph 128 ofPlaintiffs Complaint states a legal
conclusion and requires no
response. To the extent Paragraph 128 purports to allege facts,
these Defendants deny those
allegations.
129. Paragraph 129 ofPlaintiffs Complaint states a legal
conclusion and requires no
response. To the extent Paragraph 129 purports to allege facts,
these Defendants deny those
allegations.
130. These Defendants deny the allegations contained in
Paragraph 130 of Plaintiffs
Complaint.
131. These Defendants deny the allegations contained in
Paragraph 131 of Plaintiffs
Complaint.
COUNT VDECLARATORY AND INJUNCTIVE RELIEF FOR VIOLATION
OFPLAINTIFFS FIRST AND FOURTEENTH AMENDMENT RIGHTS
132. These Defendants incorporate by reference as though fully
set forth herein, their
answers to the allegations contained in Paragraphs 1 through 131
of Plaintiffs Complaint.
133. These Defendants deny the allegations contained in
Paragraph 133 of Plaintiffs
Complaint.
134. These Defendants deny the allegations contained in
Paragraph 134 of Plaintiffs
Complaint.
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STATE LAW CLAIMS
COUNT VIVIOLATION OF THE NEW MEXICO INSPECTION OF PUBLIC
RECORD ACT
135. These Defendants incorporate by reference as though fully
set forth herein, their
answers to the allegations contained in Paragraphs 1 through 134
of Plaintiffs Complaint.
136. These Defendants deny the allegations contained in
Paragraph 136 of Plaintiffs
Complaint.
137. These Defendants deny the allegations contained in
Paragraph 137 of Plaintiffs
Complaint.
138. These Defendants deny the allegations contained in
Paragraph 138 of Plaintiffs
Complaint.
139. These Defendants deny the allegations contained in
Paragraph 139 of Plaintiffs
Complaint.
COUNT VIIDECLARATORY AND INJUNCTIVE RELIEF FOR VIOLATION OF
THE NEW MEXICO INSPECTION OF PUBLIC RECORDS ACT
140. These Defendants incorporate by reference as though fully
set forth herein, their
answers to the allegations contained in Paragraphs 1 through 139
of Plaintiffs Complaint.
141. These Defendants deny the allegations contained in
Paragraph 141 of Plaintiffs
Complaint.
142. These Defendants admit the allegations contained in
Paragraph 142 of Plaintiffs
Complaint.
143. These Defendants deny the allegations contained in
Paragraph 143 of Plaintiffs
Complaint.
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REQUESTED RELIEF
144. These Defendants deny the Requested Relief section of
Plaintiffs Complaint.
JURY DEMAND
These Defendants demand trial by jury.
AFFIRMATIVE DEFENSES
1. The individual Defendants are entitled to qualified immunity
because they did not
violate any of Plaintiffs clearly established constitutional
rights and Defendants at all times
acted in good faith.
2. Plaintiffs First Amendment claims fail because Plaintiffs
alleged speech is not
constitutionally protected.
3. Plaintiffs Complaint fails to state a claim upon which relief
can be granted.
4. The individual Defendants may not be held liable to Plaintiff
because they had
insufficient personal involvement in the matters alleged
herein.
5. Plaintiffs claims are barred in whole or in part by
Plaintiffs own negligence or
other wrongful conduct.
6. Plaintiffs due process claims, if any, fail because he had no
protected property or
liberty interest.
7. Plaintiffs state law claims are barred by sovereign immunity,
and there is no
applicable waiver of immunity under the New Mexico Tort Claims
Act.
8. Plaintiffs state law claims are barred because Plaintiff
failed to provide timely or
proper notice as required under the New Mexico Tort Claims
Act.
9. These Defendants are not amenable to punitive damages under
state or federal
law.
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10. These Defendants reasonably and in good faith relied on the
advice of counsel.
11. Plaintiffs claims are barred by all applicable statutes of
limitation.
12. Plaintiffs alleged injuries are de minimis.
13. These Defendants did not impose any prior restraint upon
Plaintiff.
14. The meetings from which Plaintiff claims he was ejected or
banned were not
traditional or designated public forums.
15. These Defendants alleged conduct was not motivated by the
content of Plaintiffs
speech.
16. The alleged restrictions on Plaintiffs speech were content
neutral, reasonable,
served a significant government interest in maintaining decorum,
order and safety, were properly
tailored to serve the governments interest, and left Plaintiff
with ample alternative channels of
communication.
17. The alleged restrictions on Plaintiffs speech were
appropriate time, place and
manner restrictions.
Respectfully submitted,
YENSON, ALLEN & WOSICK, P.C.
Electronically signed by:
Patrick D. Allen
Attorneys for Defendants APS Board of Education,
David Robbins, Winston Brooks, Steve Tellez,
Monica Armenta and Rigo Chavez
4908 Alameda Blvd NEAlbuquerque, NM 87113-1736(505) 266-3995
(505) 268-6694 Fax
[email protected]
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CERTIFICATE OF SERVICE
I hereby certify that on this 21st day of December, 2012, the
foregoing pleading was
served via CM/ECF upon the following:
John W. BoydVincent J. Ward
Freedman, Boyd, Hollander, Goldberg, Urias & Ward, P.A.
20 First Plaza, NW, Suite 700Albuquerque, NM 87102
(505) 842-9960
[email protected]
[email protected]
Luis E. Robles
Robles, Rael & Anaya, P.C.500 Marquette Ave NW, # 700
Albuquerque, NM 87102-5346
[email protected]
Electronically signed by:
Patrick D. Allen
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