AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

The Plaintiff sued the Defendants for medical malpractice after a jury found that one of the Defendants, a doctor, was negligent, resulting in an award of $2.6 million in compensatory damages. However, the Medical Malpractice Act (MMA) capped the Plaintiff's total damages recovery at $1,535,916.15, which included $935,916.15 in stipulated medical expenses and $600,000 in nonmedical damages (paras 3-4).

Procedural History

• District Court, April 2016: Entered a $2.6 million judgment against Defendants, with interest and costs to be determined later. The court ruled the MMA's statutory cap unconstitutional (para 3).
• Siebert v. Okun, 2021-NMSC-016: The Supreme Court held the $600,000 cap on nonmedical damages constitutional, reversing the district court and remanding for proceedings consistent with its opinion (para 4).

Parties' Submissions

• Plaintiff: Argued for pre- and post-judgment interest on the entire judgment amount of $1,535,916.35, not just the capped amount for which the Defendants are personally liable (para 8).
• Defendants: Contended they should only be liable for interest on their $200,000 personal liability, with the Patient's Compensation Fund (PCF) responsible for interest on amounts above the cap (para 13).

Legal Issues

• Are pre- and post-judgment interest recoverable on the capped amount plus the excess, or only on the capped amount?
• Must the liable provider pay only the interest on the capped amount, or also on the excess, even though the PCF is liable for amounts over the statutory cap?
• Did the district court err in determining when post-judgment interest stopped accruing?

Disposition

• Interest is recoverable on the total of the capped amount and the excess (para 1).
• Interest must be allocated between the provider and the PCF according to their liability for damages under the MMA (para 1).
• The district court's ruling on when post-judgment interest stopped accruing is affirmed (para 32).

Reasons

Per Ives J. (Hanisee and Henderson JJ. concurring):

• The court held that interest is recoverable on the entire judgment amount, including the excess over the cap, as the MMA does not disallow interest or require a different calculation method (paras 8-12).
• The court determined that liability for interest should be allocated between the Defendants and the PCF in line with their respective liabilities for damages under the MMA. The PCF must pay interest on the amount exceeding the provider liability cap (paras 13-14).
• The court found that the PCF does not have sovereign immunity from paying interest under Section 56-8-4(D) because the PCF is not considered "the state" and its funds are not public funds (paras 15-20).
• The court affirmed the district court's decision on the accrual of post-judgment interest, as the Defendants did not provide sufficient evidence to show the tender was unconditional (paras 27-32).