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New Mexico Court of Appeals decision in Estes v. Wadley underlines documentation and limits of ADA accommodations

New Mexico Courts · March 13, 2026
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Summary

Professor Bruce Adelson highlighted Estes v. Wadley, where the New Mexico Court of Appeals held the trial court's individualized evaluation and accommodations were sufficient and clarified that appointment of a guardian ad litem is not an ADA-mandated accommodation.

Professor Bruce Adelson reviewed Estes v. Wadley, a recent New Mexico Court of Appeals opinion, and told New Mexico judiciary staff that the decision is a useful model for how courts should document and evaluate accommodation requests.

Adelson said the appeals court found the district court's process — a detailed, documented evaluation of each…

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