The ruling in the landmark Yazzie/Martinez lawsuit identifies gaps in the state's nearly 200-page plan but rejects demands for a complete rewrite, leaving major decisions for the incoming administration.

Damien Willis, Organ Mountain News

SANTA FE - A New Mexico judge has ruled that the state's plan to correct longstanding constitutional violations in public education remains incomplete, ordering the Public Education Department to address significant gaps by March 26, 2027, as a new governor prepares to take office.

First Judicial District Judge Matthew J. Wilson issued the 39-page order Nov. 2 in the consolidated Yazzie/Martinez lawsuit, more than eight years after the state was found to have failed to provide a constitutionally sufficient education to Native American students, English learners, students with disabilities and students from low-income families.

Wilson determined that PED's nearly 200-page remedial action plan, submitted in November 2025, addressed some requirements but left others unresolved. He ordered the department to supplement the plan and explicitly connect its proposed remedies to the constitutional violations identified in earlier decisions.

The ruling gives Governor-elect Deb Haaland's incoming administration a significant education policy challenge during its first legislative session.

Court identifies gaps in state education plan

Among the deficiencies Wilson identified were the plan's treatment of smaller class sizes, summer school programs intended to prevent learning loss, teacher evaluations and textbook funding.

The court found that PED had not clearly explained how it had addressed or intended to address those areas.

The judge also criticized the plan's organization, finding that its structure made it difficult to determine which proposed actions corresponded to specific court orders and constitutional violations.

PED must now prepare a supplement explaining how the state has addressed or will address the missing requirements, along with measures for determining whether those actions have been completed.

The department must also create a comprehensive overview linking its original plan and supplemental actions to the issues, violations and injunctions established by the court.

Failure to comply could result in sanctions, Wilson warned.

The plaintiffs have until April 23, 2027, to object to the supplemental filing.

Judge rejects broader demands from plaintiffs

Although Wilson agreed that the state's plan was not comprehensive, he declined to grant several additional remedies requested by the Yazzie and Martinez plaintiffs.

In objections filed earlier this year, plaintiffs argued that the plan lacked enforceable commitments, clear implementation strategies, sufficient funding analysis and meaningful participation from the communities most affected.

They sought a more extensive revision developed with the assistance of education experts and greater involvement from students, families, school districts and tribal governments.

Wilson rejected the request to rewrite the plan from the beginning, concluding that its existing content could be supplemented.

He also disagreed with the plaintiffs' contention that the plan lacked actionable measures, noting that it contained general metrics, goals and benchmarks for tracking progress through 2028.

The court declined to require detailed budgeting or dictate the state's funding decisions, citing the constitutional separation of powers among the judicial, legislative and executive branches.

And while plaintiffs challenged PED's engagement with stakeholders, Wilson found that the department had satisfied the participation requirement established in his May 2025 order.

The judge distinguished that requirement from the more extensive collaboration sought by the plaintiffs.

Advocates seek a different approach under Haaland

The New Mexico Center on Law and Poverty, which represents Yazzie plaintiffs, welcomed the finding that PED's plan was incomplete but expressed disappointment that the court did not require broader collaboration or a comprehensive analysis of the resources needed for reform.

Melissa Candelaria, the center's education director and an attorney for the plaintiffs, said the incoming administration has an opportunity to change how the state approaches the litigation.

"Rather than continuing with piecemeal revisions, the incoming administration can help forge a lasting solution grounded in the expertise of the students, families, Tribes, educators, and communities most affected," Candelaria said.

Regis Pecos, chair of the Tribal Education Alliance, similarly urged greater cooperation with tribal governments, families and educators as the state works toward constitutional compliance.

Loretta Trujillo, executive director of Transform Education New Mexico, emphasized the years students have spent in public schools while the litigation continued.

"Eight years have passed, and thousands of New Mexico students have continued moving through our public schools without seeing the changes and resources they were promised," Trujillo said.

The organizations said the next administration should prioritize meaningful changes in classrooms, including culturally and linguistically appropriate instruction, qualified educators and adequate educational resources.

More than eight years after the original ruling

The consolidated Yazzie/Martinez litigation began in 2014, when families and school districts challenged whether New Mexico was providing sufficient educational opportunities to students facing systemic disadvantages.

In 2018, the court found that the state was violating students' constitutional rights. A final judgment followed in 2019.

After additional litigation over the state's response, Wilson issued a May 20, 2025, order finding that New Mexico remained out of compliance and directing PED to prepare a comprehensive remedial action plan.

PED submitted its revised plan Nov. 3, 2025. The department describes the plan as a coordinated approach to improving instruction, educator preparation, student services and accountability, incorporating stakeholder feedback.

The latest order does not invalidate those efforts, but it finds that the plan still fails to fully account for the court's previous requirements.

The Albuquerque Journal reported Thursday that a PED spokesperson had not immediately responded to its request for comment on the ruling.

Wilson's March 26 deadline follows New Mexico's 2027 legislative session, which begins Jan. 19. The timing places responsibility for the next submission with the administration taking office in January.

For the students and families whose educational rights are at the center of the litigation, the question remains whether the next plan will translate the state's commitments into measurable improvements in their schools.

Damien Willis is founder and editor of Organ Mountain News. If you have a personal story to share or a lead we should follow up on, reach out at OrganMountainNews@gmail.com or connect with him on X at @damienwillis.