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STATE OF NEW MEXICO
IN
THE SECOND JUDICIAL DISTRICT
COUNTY OF BERNALILLO
NEW
MEXICO VOICES FOR CHILDREN,
ENLACE COMUNITARIO,
SOUTHWEST ORGANIZING PROJECT,
NATIONAL INDIAN YOUTH COUNCIL,
ALBUQUERQUE METRO NATIVE AMERICAN COALITION
PLAINTIFFS,
vs.
No.
THE
REGENTS OF THE
UNIVERSITY OF NEW MEXICO, D/B/A
THE
UNIVERSITY OF NEW MEXICO
HEALTH SCIENCES CENTER, AND
SANDRA BEGAY-CAMPBELL,
DOUGLAS BROWN,
MEL
EAVES,
JACK
FORTNER,
JAMES KOCH,
ROSALYN NGUYEN,
RAYMOND SANCHEZ,
IN
THEIR OFFICIAL CAPACITIES
DEFENDANTS.
COMPLAINT FOR VIOLATION OF CIVIL RIGHTS
AND DECLARATORY AND INJUNCTIVE RELIEF
Plaintiffs for their Complaint state:
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This
is an action for declaratory and prospective injunctive relief arising from
the University of New Mexico Health Sciences Center’s (hereinafter “UNMH”)
discrimination against non-English speaking residents of New Mexico, including
those whose primary language is Spanish, Vietnamese, Navajo, and other
languages. Defendants have failed to provide sufficient language interpreters
and translation services in order to ensure effective communication and
ultimately effective medical treatment, as well as to ensure that plaintiffs’
members are able to intelligently consent to medical treatment. By failing
to provide medical interpretation services, defendants are violating
plaintiffs’ members’ civil rights, specifically Title VI of the Civil Rights
Act, 42 U.S.C. § 2000d, 42 U.S.C. Sec. 1983, 42 U.S.C. Sec. 1981, as well as
the equal protection and due process clauses of the United States
Constitution, and the equal protection, due process and inherent rights
clauses of the New Mexico Constitution. This action is brought under 42 U.S.C.
§ 1983, 42 U.S.C. § 1981, and 42 U.S.C. § 2000d.
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Pursuant to N.M. Stat. Ann. § 44-6-1 to § 44-6-15 (Repl. Pampl. 1978), the New
Mexico Declaratory Judgment Act, as well as 28 U.S.C. § 2201, plaintiffs seek
a declaratory judgment. An actual controversy exists between the parties
because, despite notice to the defendants of their legally insufficient
interpretation services, defendants continue to violate plaintiffs’ members’
rights secured by the New Mexico and United States Constitutions and by
federal law by failing to implement a legally sufficient interpretation and
translation delivery system. Plaintiffs seek a declaration that the manner in
which the defendants are operating UNMH without legally sufficient
interpretation services violates their rights under the Fourteenth Amendment
to the United States Constitution, as protected by 42 U.S.C. § 1983, as well
as their rights under Art. II, §§ 4 and 18 of the New Mexico Constitution.
Plaintiffs also seek a declaration that defendants are violating their rights
under Title VI of the Civil Rights Act through both intentional and negligent
discrimination based on national origin due to their failure to provide
legally sufficient interpretation services. Finally, plaintiffs seek a
declaration that defendants are violating 42 U.S.C. § 1981, because defendants
are prohibiting them from receiving the full and equal benefits of the law.
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Additionally, plaintiffs seek prospective injunctive relief directing the
defendants to comply with their obligations under Title VI, 42 U.S.C. 2000d,
as well as the due process and equal protection clauses of the state and
federal constitutions, the inherent rights clause of the New Mexico
Constitution, 42 U.S.C. § 1983, 42 U.S.C. § 1981, and requiring defendants to
provide an interpretation and translation delivery system that meets the needs
of UNMH patients and the community and complies with the law. Specifically,
plaintiffs request that UNMH at a minimum: 1) identify limited English
proficient (LEP) patients; 2) develop and maintain language assistance
resources sufficient to meet the identified need; 3) implement procedures for
providing language assistance; 4) train personnel on these procedures; 5)
inform patients of their right to interpretation services; 6) implement an
accessible complaint procedure with adequate review; 7) provide signage and
translation of documents; 8) recruit bi-lingual staff; and 9) develop
monitoring and reporting requirements and procedures.
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This
Court has original jurisdiction over this matter, pursuant to the N.M.
Constitution, Art. VI, Section 13; N.M. Stat. Ann. § 38-3-1.1 (Cum. Supp.
1994); § 44-6-2 (Repl. Pamp. 1978) and 42 U.S.C. § 1983. Venue is proper
pursuant to NMSA § 38-3-1(G) (Cum. Supp. 1994).
PARTIES
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Plaintiff New Mexico
Voices for Children (“Voices”) is a private, non-profit membership
organization incorporated and located in Albuquerque, New Mexico. Voices is
formerly known as the New Mexico Advocates for Families and Children. Voices
has members who have been patients at UNMH and not received proper medical
interpretation as patients at UNMH.
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Plaintiff Enlace
Comunitario is a private, non-profit membership organization located and
incorporated in Albuquerque, New Mexico. Enlace Comunitario has members who
have been patients at UNMH and not received proper medical interpretation as
patients of UNMH.
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Plaintiff Southwest
Organizing Project (“SWOP”) is a non-profit membership organization
incorporated and located in Albuquerque, New Mexico. SWOP has members who
have been patients at UNMH and not received adequate medical interpretation
and translation services.
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Plaintiff National
Indian Youth Council (“NIYC”) is an Indian civil rights organization which was
founded in Gallup in 1973 and has an office in Albuquerque, New Mexico. The
NIYC has members who have been patients at UNMH and not received adequate
medical interpretation and translation services.
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Plaintiff Albuquerque
Metro Native American Coalition (“AMNAC”) is a non-profit membership
organization incorporated and located in Albuquerque, New Mexico. The AMNAC
operates exclusively to improve the healthcare of all members of federally
recognized tribes who reside in the Albuquerque, New Mexico metro area. AMNAC
has members who have been patients at UNMH and not received adequate medical
interpretation and translation services.
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Plaintiffs are
members of the Community Coalition for Health Care Access, a grassroots
coalition of community members and providers which had been negotiating with
administrators of UNMH to attempt to improve the interpretation and
translation services available at UNMH.
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Defendants, the
Regents of the University of New Mexico, are the governing body of the
University of New Mexico, which is a state educational institution named in
Article 12, Section 11 of the New Mexico Constitution. UNMH is part of the
University of New Mexico and is located in Albuquerque, New Mexico.
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Each of the
individual defendants named are Regents at the University of New Mexico. Each
is sued solely in his or her official capacity.
FACTUAL ALLEGATIONS
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Medical interpretation is a
specific skill that requires training and education in medical terminology,
language proficiency and cultural competency. In order for limited English
proficient (“LEP”) patients to enjoy equal access to medical services,
competent medical interpretation and translation of written materials must be
provided by the health care facility.
-
Upon
information and belief, UNMH has received numerous complaints from private
parties concerning their failure to provide adequate interpretation services.
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The
Community Coalition for
Health Care Access and plaintiffs have also received numerous complaints about
UNMH’s interpretation services, including: 1) LEP patients who requested, but
were refused interpreters; 2) children of LEP patients being asked to
interpret medical conditions for their parents; 3) LEP patients who were not
provided interpreters to explain their own or their children’s medical
conditions; 4) LEP patients who were provided discharge and medication
instructions in English, who suffered adverse medical consequences from not
being able to understand the instructions.
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Since
at least 1997, UNMH has received notice of the lack of competent and legally
sufficient interpretation services for LEP patients.
-
In
July of 1997, community health workers with the Community Health Partnership (CHP)
program, a project of Voices, began documenting language-based discrimination
at UNMH.
-
In the
fall of 1997, CHP reported their concerns about the lack of interpretation and
translation services, i.e. language discrimination, to the University Hospital
Patient Ombudsman, the Office of Risk Management and the Department of Human
Resources.
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In
response, UNMH contracted with an outside agency to provide bi-lingual staff
with a six hour preliminary training in medical interpretation skills.
However, no additional efforts were made by UNMH to solve the problem and
reports of patients problems related to language discrimination continued
unabated.
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In the
fall of 1998, CHP and Voices, then known as New Mexico Advocates for Children
and Families, again met with UNMH administrators from the Department of
Ambulatory Services and provided documentation of the on-going interpreter
problems, as well as the OCR Guidance Memo regarding Title VI of the 1964
Civil Rights Act and a list of recommendations for effective interpreter
services. This meeting resulted in several follow up meetings.
-
During
1998, and the first part of 1999, CHP and Voices met with administrators from
Ambulatory Services, Human Resources and Risk Management, wherein
administrators acknowledged that UNMH was not providing adequate and
appropriate language assistance to LEP patients.
-
In
response, the six-hour training was repeated, UNMH hired eight on-call
language interpreters, and Ambulatory Services agreed to reorganize patient
record systems to include a file for patient language of preference.
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In the
summer of 1999, as interpretation and translation problems continued, CHP and
Voices continued to call UNMH administrators for follow-up meetings, but the
administrators did not return those calls.
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In March
of 2000, Voices, on behalf of its LEP clients, filed a discrimination
complaint (hereinafter “OCR complaint”) against UNMH with the federal
Department of Health and Human Services’ Office of Civil Rights. The OCR
complaint alleged that the hospital discriminated against patients on the
basis of national origin because people of Mexican, Vietnamese, Cuban, and
Navajo descent encountered exceptional difficulties in obtaining safe,
professional and effective treatment at the hospital as compared to patients
proficient in the English language.
-
As a
result of the OCR complaint, in March of 2002, a team of investigators from
the OCR, Region VI came to UNMH to evaluate the interpreter services. Days
before the investigators arrived, UNMH set up the Interpreter Services Program
and hired a few interpreters. This program, although an improvement, is not
legally sufficient to respond to the language needs of the LEP patients in the
community.
-
The OCR
complaint is still “open” and although UNMH now has an Interpreter Services
Program with a few hired interpreters, serious interpretation problems
continue to result in discrimination against LEP patients.
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In
2001, the Community Coalition for Health Care Access (the “CCHA”), a coalition
of community groups and individuals, was formed. In 2002, the CCHA provided
UNMH with a list of ten demands, one of which was to “ensure that adequate and
professional translation and interpretation services are provided to all
patients who have limited proficiency in reading and/or speaking English.”
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In 2003,
the CCHA held two community meetings in which community members gave testimony
regarding the difficulties they had accessing services at UNMH. At the June
2003 meeting, in which UNMH CEO Stephen McKernan was present, several
Vietnamese-speaking individuals testified that they were not provided
interpretation services for their medical appointments.
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In 2004,
representatives of the CCHA began regular meetings with Mr. McKernan, and
other administrators, regarding a variety of access to health care problems,
including inadequate interpretation services.
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During a
meeting on February 16, 2004, in response to the CCHA’s request that UNMH
increase the number of qualified interpreters, Mr. McKernan acknowledged that
the current translation / interpretation services at UNMH were inadequate.
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On
February 27, 2004, the CCHA proposed that UNMH increase the number of
interpreters by adding three additional Spanish, one Vietnamese and one
Navajo, in order to provide patients with greater access to qualified
interpretation services.
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During a
meeting on March 17, 2004, Mr. McKernan handed out a one-page document that he
called a “gap analysis” that showed that 8439 requests for interpreters had
been made in 2003, and that 1066 of those requests had not been met. The
document also showed that 46,208 patients were entered into the UNMH’s master
scheduling program, identified as LEP patients in need of Spanish
interpretation in 2003. At this meeting, Mr. McKernan again agreed that the
interpretation services needed improvement and that further evaluation was
needed.
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On May
28, 2004, representatives from the CCHA met with the UNMH Administrators and
the Clinical Operations Board Subcommittee on Advocacy and Community Relations
to discuss, inter alia, the on-going interpretation problems. At that
meeting a letter from providers at the Southeast Heights Clinic, supporting
the increase in the number of full-time interpreters, was presented to the
administration and members of the subcommittee. Mr. McKernan agreed to submit
a request for three more Spanish interpreters to the budget committee.
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At the
June 14, 2004 meeting, Mr. McKernan stated that three new positions for
Spanish interpreters were approved and that the jobs would be posted on July
1, 2004.
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On July
15, 2004, the New Mexico Center on Law & Poverty sent a letter to the members
of the Clinical Operations Board requesting that the Board require UNMH to
conduct a comprehensive and in-depth evaluation of their interpreter services.
There was no response to this letter.
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At the
July 19, 2004 negotiation meeting, Mr. McKernan stated that no new
interpreters had yet been hired.
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On
August 6, 2004, representatives from the CCHA made a public comment at the
UNMH Clinical Operations Board (“COB”) monthly meeting regarding the lack of
response by the administration to the interpreter problem. CCHA pointed out
that the UNMH administrative policy entitled “Language Interpreter Services”
specifies that the management will conduct an evaluation every three years,
but had never done one.
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At the August 16, 2004
negotiation meeting, Mr. McKernan stated that no new interpreters had yet been
hired.
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On August 27, 2004, the CCHA
met with the members of the COB subcommittee to discuss improving the
interpretation services. At that meeting, the UNMH administration and the
subcommittee agreed to form a working group to conduct an evaluation of the
interpreter services, but refused to allow a community member to participate.
Instead, the COB subcommittee members stated they would accept written
information.
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At the August 27, 2004
meeting, Steve McKernan stated that only one new Spanish interpreter had been
hired and that this position was a supervisory position.
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On October 5, 2004, the New
Mexico Center on Law & Poverty provided the UNMH administration and the
subcommittee with a lengthy document with attachments that outlined UNMH’s
legal responsibility to the LEP community, as well as detailed examples of the
components of model interpretation programs. UNMH did not respond to this
document.
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In November 2004, the CCHA
ended the negotiations with Mr. McKernan, because, inter alia,
insufficient progress had been made to improve the interpretation services.
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On December 3, 2004, an
attorney from the N.M. Center on Law and Poverty spoke at a joint Board of
Bernalillo County Commissioners / Clinical Operations Board meeting about,
inter alia, the inadequate interpretation services at UNMH and the
resulting violations of federal law and patients’ civil rights.
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Despite years of notice to
UNMH that the interpreter delivery system is in violation of the law, as well
as multiple admissions that the system is inadequate, the language barriers
persist.
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Upon information and belief, currently there are only five Spanish
interpreters, one half-time Navajo and one Vietnamese interpreter. These
interpreters do not meet the needs of the patients, and therefore, LEP
patients’ civil rights are regularly violated. Moreover, there are no
qualified interpreters available on the weekends, or outside of regular
business hours during the week. Instead, UNMH relies on untrained or
inadequately trained bi-lingual staff, a telephonic interpretation system, and
the help of patients’ family and friends.
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During 2003, approximately 46,000 new patients were identified as needing
language assistance when they first encountered UNMH. However, during that
same year, only 8439 requests for interpreters were made. This means that
approximately 38,000 people who were originally identified as needing an
interpreter somehow went through the system without even asking for one, let
alone getting one.
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During the first half of 2004 alone, UNMH identified approximately 27,000
people as needing language assistance. Given the number of interpreters at
UNMH, and the statistics from the year before, it is clear that most of those
people received their medical care without a medical interpreter.
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In 2004, there were 6,492 requests for in-person interpretation and 1,521 went
unmet. Although fewer requests were recorded in 2004 than in 2003, more
requests for interpretation were unmet.
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In 2004, 7,120 calls were made to the telephone interpretation service to
request Spanish interpretation. 1,098 calls were made to the telephone
interpretation service to request Spanish interpretation for patients at the
Women’s Care Unit alone, at a cost of $21,818. The volume of calls for this
frequently encountered language indicates a failure to provide in-person
interpretation at the required population threshold.
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In 2004, 344 calls to the telephonic interpretation service were made
requesting Vietnamese interpretation. From July to December 2004, the one
Vietnamese interpreter on staff was unable to meet 155 requests for in-person
interpretation.
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UNMH’s reliance on a telephonic interpretation system for frequently
encountered languages, such as Vietnamese and Spanish, is also legally
insufficient and amounts to a violation of LEP patients’ civil rights.
Telephonic interpretation should only be used as a last resort because of the
privacy concerns; moreover, accurate interpretation includes clues from facial
expressions and body language. Many clinical areas are not equipped with
speaker phones that would permit telephonic interpretation. Although the
telephonic system may be necessary for languages which are rare in the
community, the telephonic system cannot replace the skills of an in-person
medical interpreter.
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UNMH’s reliance on bi-lingual staff to provide interpretation services is
legally insufficient and amounts to a violation of LEP patients’ civil
rights. Bi-lingual staff members have other responsibilities and cannot meet
the interpretation needs of the patients. Moreover, most of this staff
receives no training in medical interpretation and, therefore, is not
qualified to do medical interpretation.
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UNMH’s reliance on patients’ family members, friends and other patients is not
only illegal, it also violates patient confidentiality. Family and friends
with no medical training are unable to interpret medical terminology.
Children are being asked to interpret serious medical conditions for their
parents. Moreover, privacy is violated, and family members are put in
uncomfortable positions of needing to interpret extremely private or difficult
news to a loved one.
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UNMH has an obligation to fully assess the language needs of the residents of
Bernalillo County and New Mexico. According to the 2000 Census, nearly 48,000
residents in Bernalillo County reported that they speak English “less than
very well.” Yet, the hospital has failed to study, let alone implement an
interpretation delivery system that meets the needs of thousands of county
residents.
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At all material times, the
defendants acted under color of state law.
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Defendants have intentionally failed to provide interpretation services
required by federal and state laws.
COUNT I – VIOLATION OF TITLE
VI, 42 U.S.C. § 2000d AND 42 U.S.C. § 1983
FOR INTENTIONAL
DISCRIMINATION BASED ON NATIONAL ORIGIN
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Plaintiffs incorporate by reference all preceding allegations as if fully set
forth herein.
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Plaintiffs bring this claim against all defendants.
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UNMH receives federal financial assistance as defined in 45 C.F.R. 80.13(f).
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As a recipient of federal financial assistance from the U.S. Department of
Health and Human Services, UNMH is subject in all of its programs to Title VI
of the Civil Rights Act of 1964 and its implementing regulations.
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Title VI prohibits discrimination by a medical facility on the basis of
national origin. Title VI provides: “No person in the United States shall on
the ground of race, color, or national origin be excluded from participation
in, be denied the benefits of, or be subjected to discrimination under any
program or activity receiving Federal financial assistance.” 42 U.S.C. §
2000d.
-
Section 602 of the Civil Rights Act authorizes agencies “to effectuate the
provisions of [Section 601] … by issuing rules, regulations or orders of
general applicability.” 42 U.S.C. § 200d-1.
-
The Title VI regulations provide, in part, that “[a] recipient … may not,
directly or through contractual or other arrangements, utilize criteria or
methods of administration which have the effect of subjecting individuals to
discrimination because of their race, color, or national origin or have the
effect of defeating or substantially impairing accomplishments of the
objective of the program in respect to individuals of a particular race, color
or national origin.” 45 C.F.R. § 80.3(b).
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The Title VI statute
and regulations place an affirmative responsibility on federal fund
recipients, such as UNMH, to adopt and implement policies and procedures that
do not intentionally exclude or limit or have the effect of excluding or
limiting the participation of LEP persons in their program’s benefits or
activities on the basis of race, color or national origin.
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By continually failing to provide sufficient translation and interpretation
services, including the failure to obtain informed consent in a patients’
native language, despite years of notice that a serious problem exists, UNMH
intentionally discriminates against plaintiffs’ members by reason of their
national origin.
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The policies and practices of the Regents of the University of New Mexico,
acting in their official capacities and through UNMH, continue to discriminate
against plaintiffs’ members based on national origin.
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Plaintiffs each have members who are LEP individuals who have required and/or
who are likely to require medical care from UNMH in the future. Plaintiffs’
members’ medical care will therefore be adversely affected by the failure of
UNMH to provide adequate medical interpretation and translation services and
plaintiffs’ members will suffer discrimination.
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As a result of defendants’ actions, plaintiffs are entitled to a declaratory
judgment that defendants have violated Title VI and an order enjoining
defendants from continuing to violate Title VI and § 1983 due to their failure
to provide legally sufficient interpretation services.
COUNT II – VIOLATION OF 42
U.S.C. § 1983: FAILURE TO PROVIDE A LEGALLY SUFFICIENT INTERPRETATION DELIVERY
SYSTEM IN VIOLATION OF 42 U.S.C. 2000d.
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Plaintiffs incorporate by reference all preceding allegations as if fully set
forth herein.
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Defendants’ violation of federal law has had a disparate impact on plaintiffs’
members, resulting in a violation of 42 U.S.C. § 1983.
-
Title VI and its implementing regulations are intended to benefit the
plaintiffs’ members.
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The rights established under Title VI and its implementing regulations are
clear and specific and impose a binding obligation on the state.
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Defendants’ failure to provide adequate interpretation services violates Title
VI of the Civil Rights Act, 42 U.S.C. § 2000d and its implementing
regulations, 45 C.F.R. § 80 et seq., and thus constitutes a violation of 42
U.S.C. § 1983.
- As a result of
defendants’ actions, plaintiffs are entitled to a declaratory judgment that
defendants have violated 42 U.S.C. § 2000d and its implementing regulations,
45 C.F.R. § 80 et seq. and an order enjoining defendants from continuing to
violate 42 U.S.C. § 2000d due to their failure to provide legally sufficient
interpretation services.
COUNT III -- VIOLATION OF 42
U.S.C. § 1983: DISCRIMINATION BASED ON NATIONAL ORIGIN RESULTING IN EQUAL
PROTECTION VIOLATION
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Plaintiffs incorporate by reference all preceding allegations as if fully set
forth herein.
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Defendants are violating plaintiffs’ members’ right to equal protection under
the law, as guaranteed by the 14th Amendment to the United States
Constitution, in violation of 42 U.S.C. § 1983.
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Plaintiffs’ members are
members of a suspect class because they have been discriminated against based
on national origin.
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Defendants have
discriminated against plaintiffs’ members by failing to provide language
interpretation to ensure the fundamental right to emergency and medically
necessary treatment.
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Defendants do not possess a
compelling state interest that would justify discrimination against the
plaintiffs’ members.
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Plaintiffs’ members have suffered harm, and will continue to suffer
irreparable harm for which there is no adequate remedy at law as a direct and
proximate result of the defendants’ violations of plaintiffs’ members’
federally guaranteed rights to receive legally sufficient interpretation
services.
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As a result of defendants’
actions, plaintiffs are entitled to a declaratory judgment that defendants
have violated plaintiffs’ members’ right to equal protection under the law, as
guaranteed by the 14th Amendment to the United States Constitution,
in violation of 42 U.S.C. § 1983, and an order enjoining defendants from
continuing to violate plaintiffs’ members’ right to equal protection due to
their failure to provide legally sufficient interpretation services.
COUNT IV – VIOLATION OF 42 U.S.C. § 1983: VIOLATION OF SUBSTANTIVE DUE
PROCESS RIGHTS
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Plaintiffs incorporate by reference all preceding allegations as if fully set
forth herein.
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Defendants are violating plaintiffs’ members’ substantive due process rights,
as guaranteed by the 14th Amendment to the United States
Constitution, in violation of 42 U.S.C. § 1983.
-
Plaintiffs’ members have
failed to receive language interpretation for both emergency and medically
necessary treatment. As a result, plaintiffs’ members have been denied the
fundamental right to access and receive medical treatment, in violation of the
due process clause.
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Plaintiffs’ members have
suffered harm, and will continue to suffer irreparable harm for which there is
no adequate remedy at law as a direct and proximate result of the defendants’
violation of plaintiffs’ members’ federally guaranteed rights to receive
adequate interpretation services.
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As a result of defendants’ actions, plaintiffs are entitled to a declaratory
judgment that defendants have violated plaintiffs’ members’ right to
substantive due process under the law, as guaranteed by the 14th
Amendment to the United States Constitution, in violation of 42 U.S.C. § 1983,
and an order enjoining defendants from continuing to violate plaintiffs’
members’ right to substantive due process due to their failure to provide
legally sufficient interpretation services.
COUNT V
– VIOLATION OF 42 U.S.C. § 1981: VIOLATION OF PROTECTED INTEREST BASED ON
NATIONAL ORIGIN
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Plaintiffs incorporate by
reference all preceding allegations as if fully set forth herein.
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42 U.S.C. § 1981 provides that “[a]ll persons have equal rights to make and
enforce contracts … to the full and equal benefits of all laws and proceedings
for the securing of persons and property as is enjoyed by white citizens.”
-
Defendants’ actions constitute intentional discrimination based on national
origin against plaintiffs’ members. The discrimination has interfered with
the plaintiffs’ members’ rights to the full and equal benefits of the laws, in
violation of 42 U.S.C. § 1981.
-
As a result of defendants’
actions, plaintiffs are entitled to a declaratory judgment that defendants
have violated plaintiffs’ members’ right to the full and equal benefits of the
law, in violation of 42 U.S.C. § 1981, and an order enjoining defendants from
continuing to violate plaintiffs’ members’ right to the full benefits of the
law due to their failure to provide legally sufficient interpretation
services.
COUNT VI - VIOLATION OF THE STATE INHERENT RIGHTS CLAUSE
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Plaintiffs incorporate by reference all preceding allegations as if fully set
forth herein.
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Art. II, Sec. 4 of the New
Mexico Constitution provides: “All persons are born equally free, and have
certain natural, inherent and inalienable rights, among which are the rights
of enjoying and defending life and liberty, of acquiring, possessing and
protecting property, and of seeking and obtaining safety and happiness.”
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By failing to provide LEP patients with adequate medical interpretation,
defendants violate plaintiffs’ members’ inherent and inalienable rights of
life, liberty, safety, and happiness by impermissibly infringing on
plaintiffs’ members’ exercise of the pursuit of medical treatment as
guaranteed by the inherent rights clause.
-
As a result of defendants’ actions, plaintiffs are entitled to a declaratory
judgment that defendants have violated the state inherent rights clause, and
an order enjoining defendants from continuing to violate plaintiffs’ members’
right to life, liberty, safety and happiness due to their failure to provide
legally sufficient interpretation services.
COUNT VII – VIOLATION OF THE STATE EQUAL PROTECTION CLAUSE
-
Plaintiffs incorporate by reference all preceding allegations as if fully set
forth herein.
-
Article II, Section 18 of the New Mexico Constitution provides in relevant
part that no person “shall … be denied equal protection of the laws.”
-
Plaintiffs’ members are
members of a suspect class based on national origin.
-
Defendants’ have discriminated against plaintiffs’ members by failing to
provide language interpretation to ensure the fundamental right to emergency
and medically necessary treatment.
-
Defendants do not possess
a compelling state interest that would justify discrimination against the
plaintiffs’ members.
-
As a result of defendants’
actions, plaintiffs are entitled to a declaratory judgment that defendants
have violated plaintiffs’ members’ state equal protection rights, and an order
enjoining defendants from continuing to violate plaintiffs’ members’ state
equal protection rights due to their failure to provide legally sufficient
interpretation services.
COUNT VIII – VIOLATION OF STATE SUBSTANTIVE DUE
PROCESS CLAUSE
-
Plaintiffs incorporate by
reference all preceding allegations as if fully set forth herein.
-
Article II, Section 18 of
the New Mexico Constitution provides in relevant part that “[n]o person shall
be deprived of life, liberty or property without due process of law…”
-
Plaintiffs' members have
failed to receive language interpretation for both emergency and medically
necessary treatment. As a result, plaintiffs’ members have been denied the
fundamental right to access and receive medical treatment, in violation of the
due process clause.
-
As a
result of defendants’ actions, plaintiffs are entitled to a declaratory
judgment that defendants have violated plaintiffs’ members’ state substantive
due process rights, and an order enjoining defendants from continuing to
violate plaintiffs’ members’ state substantive due process rights due to their
failure to provide legally sufficient interpretation services.
WHEREFORE, plaintiffs respectfully request that the
Court:
1. Issue a Declaratory
Judgment declaring that the defendants’ actions result in intentional
discrimination against plaintiffs’ members based on national origin, violate the
United States Constitution’s equal protection and due process clauses, Title VI
of the Civil Rights Act, 42 U.S.C. Sections 2000d, 1983 and 1981, and the New
Mexico Constitution’s inherent rights, equal protection and due process clauses;
and
2. Order immediate injunctive
relief, ordering the defendants to implement a language access delivery system
which shall include at a minimum:
A. An assessment of the medical language needs of
UNMH’s patients;
B. Identification of LEP patients at registration or
admission, as well as tracking to ensure
interpretation services are available throughout all medical
procedures;
C. Provision of legally sufficient language assistance
services, including interpretation and translation services outside of regular
business hours, the hiring of additional trained medical interpreters and
contracting with trained medical interpreters for less frequently encountered
languages;
D. Development of policies and procedures to ensure that LEP
patients are secured language assistance services;
E. Training and education for staff on language
assistance policies and procedures;
F. Information to patients of their language assistance
rights;
G. Complaint procedures for staff and patients, with
adequate review.
H. Sufficient foreign language signage and translation
of documents;
I. Recruitment of bi-lingual staff; and rigorous
medical interpretation training of any bi-lingual staff
before being
used as a medical interpreter;
J. Ongoing monitoring of the language needs of UNMH patients
to ensure that they continue to be met, with on-going input from the community
and reporting to the public on the status of the language interpretation and
translation delivery system at UNMH.
3. Award reasonable attorneys’ fees and costs, pursuant to
42 U.S.C. § 1988.
4. Order any other such relief as the Court deems just and
proper.
RESPECTFULLY SUBMITTED,
Gail Evans, Legal Director
New Mexico Center on Law Poverty
Attorney for plaintiffs
3117 Silver Ave. S.E.
Albuquerque, New Mexico 87106
Phone: (505) 255-2840
Fax: (505) 255-2778
Maureen Sanders
Co-legal Director of NMCLF
Sanders & Westbrook, P.C.
Attorney for plaintiffs
102 Granite N.W.
Albuquerque, New Mexico 87102
Phone: (505) 243-2243
Fax: (505) 243-2750
Nancy Simmons,
Cooperating Attorney of NMCLF
Attorney for Enlace Communitario
122 Tulane S.E.
Albuquerque, New Mexico 87106
Phone: (505) 255-2575
Fax: (505) 232-2574
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