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In Davis v. The Board of County Commissioners of Dona Ana County, an employer provided a reference for a former employee—a detention sergeant—describing him as a "pleasure to work with," and an "excellent" employee even though the employer had been planning to place the employee on an unpaid disciplinary suspension as a result of an investigation into allegations of inappropriate sexual behavior with female inmates. He was subsequently hired by a psychiatric facility, where he was accused of sexually and physically assaulting a patient over a period of two weeks. The patient sued the former employer for negligent misrepresentation because of the misinformation supplied by the detention center about the employee.
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