State of New Mexico County of Bernalillo First Judicial District Court
STATE OF NEW MEXICO COUNTY OF BERNALILLO FIRST JUDICIAL DISTRICT COURT STATE OF NEW MEXICO EX REL. THE HONORABLE MIMI STEWART, THE HONORALBE SHERYL WILLIAMS STAPLETON, THE HONORABLE HOWIE C. MORALES, THE HONORALBE LINDA M. LOPEZ, THE HONORABLE WILLIAM P. SOULES, AMERICAN FEDERATION OF TEACHERS— NEW MEXICO, ALBUQUERQUE FEDERATION OF TEACHERS, JOLENE BEGAY, DANA ALLEN, NAOMI DANIEL, RON LAVANDOSKI, TRACEY BRUMLIK, CRYSTAL HERRERA, and ALLISON HAWKS, Plaintiffs, v. No. ____________________ NEW MEXICO PUBLIC EDUCATION DEPARTMENT and SECRETARY-DESIGNEE HANNA SKANDERA in her official capacity, Defendants. COMPLAINT FOR DECLARATORY JUDGMENT AND PRELIMINARY AND PERMANENT INJUNCTIVE RELIEF COME NOW, Plaintiffs, by and through the undersigned, and for their Complaint against Defendants state as follows: I. INTRODUCTION 1. Plaintiffs bring this action against the Public Education Department and its Secretary-Designee, in her official capacity only, because Defendants have implemented a fundamental change in the manner in which teachers are evaluated in New Mexico. As detailed in this Complaint, that change is based on a fundamentally, and irreparably, flawed methodology which is further plagued by consistent and appalling data errors. As a result, teachers are being evaluated, and employment decisions made, based on a process that is, at best, arbitrary and capricious. 2. Due to the problems with the evaluation methodology detailed herein, Defendants have or are about to violate Plaintiffs’ constitutional rights, violate the statutory authority under which they operate, and violate other provisions of law. Plaintiffs seek declaratory and injunctive relief. II. PARTIES, JURISDICTION, AND VENUE 3. Plaintiff the Honorable Senator Mimi Stewart is the elected Senator from District 17 (Bernalillo County).
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