New Mexico Supreme Court

In Re Detsoi

July 10, 2026

Summary

The Court upheld the Commission’s procedures and permanent removal of the magistrate judge. It held that the Commission had broad discretion to conduct the disciplinary hearing itself rather than appoint masters, and that combining investigative and adjudicative functions does not violate due process absent unconstitutional bias and resulting prejudice. The Court also held that repeated, intentional, and bad-faith legal errors can constitute willful misconduct when they exceed mere negligence or an isolated error of judgment.