Justia New Mexico Supreme Court Opinion Summaries

Environmental contamination from Shell Western Exploration and Production, Inc. and Shell Oil Company's operations was discovered in Hobbs. Residents near the area brought a toxic tort action against Shell for personal injury damages, alleging the contaminants cause their autoimmune disorders. Plaintiffs challenged the district court's exclusion of the scientific evidence and expert testimony they offered in support of their theory, and they challenged the grant of partial summary judgment in favor of Shell. After review, the Supreme Court concluded the district court applied an incorrect standard of admissibility in its evidentiary rulings, and that plaintiffs' causation evidence should have been admitted. Because summary judgment to Shell's culpability for autoimmune disorders was granted because of this improper exclusion, the Supreme Court reversed and remanded for further proceedings. View "Acosta v. Shell W. Expl. & Prod., Inc." on Justia Law

Plaintiff Kenneth Badilla bought a pair of work boots at Wal-Mart. He claimed the soles of the boots came unglued, causing him to trip and injure his back. More than three years later, he sued Wal-Mart and its store manager (Defendants) for breach of express and implied warranties. In his complaint plaintiff sought damages for personal injuries he claims were caused by the boots’ alleged failure to conform to their warranties. Defendants moved for summary judgment, which the district court granted on two grounds: (1) that Plaintiff’s complaint was time-barred by the application of the three-year statute of limitation for causes of action for torts; and (2) that there were no genuine issues of material fact to rebut plaintiff’s inability to establish the elements for breach of express and implied warranty. The Court of Appeals affirmed the district court’s grant of summary judgment on the statute of limitations issue, and because its determination on that issue was dispositive, it abstained from addressing the second basis upon which the district court granted summary judgment. Plaintiff sought review of the Court of Appeals’ decision by petition for writ of certiorari, asking this Court to determine whether his claims for personal injury damages resulting from breach of warranties were subject to the four-year limitation period set out in Section 55-2-725 or the three-year limitation period for tort actions found in Section 37-1-8. Upon review, the Supreme Court held that the UCC’s four-year statute of limitation governed breach of warranty claims, including those seeking damages for personal injuries resulting from the breach. View "Badilla v. Wal-Mart Stores East Inc." on Justia Law

Ken Snow worked as an operator for the Navajo Refinery. During a procedure called a "turn-around" at the refinery, a hose assembly came loose and struck Snow, causing "serious, life-changing injuries." Snow and his wife filed suit against the Refinery, complaining of personal injury, loss of consortium, and asked for punitive damages. Snow named as defendants Midwest Hose & Specialty, Inc., Gandy Corporation, Repcon, Inc., and Holly Corporation as defendants. After a period of discovery, Snow sought to amend his complaint to add Warren Power & Machinery, Inc. d/b/a Warren CAT and Brininstool Equipment Sales. What this case presented for the Supreme Court's review centered on the "unusual" issue dealing with the procedure for seeking leave to amend a complaint to add parties as additional defendants. When the motion for leave is filed before the statute of limitations has run, but the order granting leave is filed after the statute has run, is the amended complaint time barred? Adopting a new rule for this situation, the Court held that the subsequently filed amended complaint, post-statute of limitations, was deemed filed as of the date of the original motion for leave to file and accordingly, the statute of limitations was not a bar. The Court of Appeals held to the contrary, and the Supreme Court reversed. View "Snow v. Warren Power & Mach., Inc." on Justia Law

In March 2007, Plaintiff Dara Hem brought suit in a Texas federal court after he was seriously injured in an accident. Hem was traveling through northern New Mexico when his Toyota truck separated from the U-Haul trailer it was towing, causing the truck to roll over several times. After treating Hem for his injuries, the University of New Mexico Hospital (UNMH) recorded a hospital lien for Hem's outstanding medical bills. The lien would attach to any future judgment or settlement he might procure from a lawsuit, pursuant to the Hospital Lien Act. Although Hem did not dispute the amount owed, UNMH agreed to compromise on the lien amount and accept a lesser amount as payment in full. In exchange, one of Hem's attorneys, Miller, agreed to give up his statutory priority over settlement funds already obtained from U-Haul and some anticipated settlement funds from Toyota, so UNMH would be paid first. The issue this case presented for the Supreme Court's review was whether the agreement UNMH made to reduce the amount of a lien for medical services rendered violated Article IV, Section 32 of the New Mexico Constitution. UNMH argued it had priority over settlement funds pursuant to the agreement between itself and Hem's initial attorney, Clay Miller. Hem's second attorney, Turner & Associates, P.A. (claimant in interpleader) argued that this agreement was unconstitutional. Therefore, Turner argued that it has a priority right to collect fees and costs out of the interpleaded settlement funds prior to the satisfaction of the hospital lien, pursuant to the Act. The New Mexico Supreme Court held that: (1) the first clause of Section 32 was correctly interpreted in State Investment and is strictly a limitation on the Legislature; and (2) Article IV, Section 32 of the New Mexico Constitution does not prohibit UNMH from agreeing to compromise the amount owed by a patient-debtor. View "Hem v. Toyota Motor Corp." on Justia Law

The issue this case presented for the Supreme Court's review was one of res judicata, and whether the preclusive effect of a fee proceeding in bankruptcy court on a later lawsuit for legal malpractice allegedly committed in the course of the bankruptcy. After review, the Court held that the elements of res judicata were met and that Petitioner was sufficiently aware of his malpractice claim, which he could and should have brought in the bankruptcy proceeding. The Court affirmed dismissal of Petitioner’s subsequent malpractice suit but emphasized that barring a claim on res judicata grounds requires a determination that the claimant had a full and fair opportunity to litigate the claim in the earlier proceeding. View "Potter v. Pierce" on Justia Law

In August 2002, plaintiff William Vaughan went to the emergency room at St. Vincent Hospital complaining of symptoms that included abdominal pain. In this medical negligence case, Vaughan alleged that, as the result of a communication failure between a surgeon and a contract radiologist, St. Vincent failed to tell Vaughan about a cancer diagnosis. The district court granted summary judgment for St. Vincent because Vaughan did not specifically plead vicarious liability relating to the radiologist, St. Vincent's apparent agent, and failed to establish a genuine issue of material fact through expert testimony. After review, the Supreme Court reversed and remanded, holding that Vaughan's complaint adequately notified St. Vincent that one or more of its employees or agents was negligent and that genuine issues of material fact required resolution at a trial on the merits. View "Vaughan v. St. Vincent Hospital" on Justia Law