Lindsay O’Brien Quarrie sued the Board of Regents for New Mexico Institute of Mining & Technology (NMT) and several individual defendants in the U.S. District Court for the District of New Mexico, alleging fraud on the court, violations of Title VI of the Civil Rights Act, retaliation, and defamation. The district court dismissed all claims under Federal Rule of Civil Procedure 12(b)(6), and Quarrie appealed to the Tenth Circuit Court of Appeals.
Factual Overview
Quarrie was a doctoral candidate at NMT until his termination from the PhD program in 2012. He filed his first lawsuit alleging racial discrimination, which was dismissed. The parties then entered into a settlement agreement that barred Quarrie from seeking readmission to NMT and required NMT to remove certain language from his transcript. After discovering NMT had added “no degree earned” to his transcript and retained copies of his termination letter, Quarrie claimed the settlement agreement was void and applied for readmission in 2017. When NMT refused to consider his application, he filed a second lawsuit alleging discrimination and other claims, which was also dismissed. In 2023, Quarrie discovered two additional copies of his termination letter that had not been disclosed during discovery in the 2017 lawsuit. He again claimed the settlement agreement was void and applied for readmission. When NMT again refused to consider his application, he filed this third lawsuit.
Legal Analysis
Fraud on the Court: The court rejected Quarrie’s claim that NMT’s failure to disclose two additional copies of the termination letter constituted fraud on the court. The court found that such nondisclosure in discovery did not rise to the level of fraud that would justify setting aside the previous judgment.
Preclusion of Claims: The court found that Quarrie’s declaratory judgment and retaliation claims were barred by collateral estoppel, as they involved the same issues decided in the 2017 litigation. His race discrimination claim was barred by res judicata because it arose from the same series of transactions as his previous lawsuit. The court determined that discovering two additional copies of the termination letter did not constitute a significant change in controlling facts that would avoid preclusion.
Defamation: The court dismissed the defamation claim against one defendant based on witness immunity for statements made during a deposition. The claim against the other defendant was dismissed because the alleged harm – delayed discharge of student loans – did not constitute deprivation of a constitutionally protected property interest.
The Tenth Circuit affirmed the district court’s dismissal of all claims.
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