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 case arose from a divorce proceeding initiated by the Petitioner-Respondent seeking the dissolution of marriage and division of community property. The trial court determined that an equal division of the community estate would be inequitable due to the earning potential and ages of the parties.
Procedural History
- District Court, August 1992: Entered a decree of divorce and retained jurisdiction over the division of property and debts.
- District Court, March 5, 1993: Issued a judgment dividing the community estate, finding that an equal division would be inequitable.
- Court of Appeals: Refused to review the sufficiency of the evidence, holding that the Respondent-Petitioner waived review by failing to file a timely request for findings of fact and conclusions of law.
Parties' Submissions
- Petitioner-Respondent: [Not applicable or not found]
- Respondent-Petitioner: Argued that the trial court erred in determining the amount of the community lien, dividing the lien, and failing to require post-judgment interest. He also contended that the "ends of justice" required remand for additional findings and conclusions.
Legal Issues
- Whether failure to make a timely request for findings of fact and conclusions of law precludes appellate review of the sufficiency of the evidence supporting a trial court's judgment.
- Whether the trial court erred in its division of the community estate and in failing to award post-judgment interest.
Disposition
- The Supreme Court of New Mexico affirmed the decisions of the Court of Appeals and the trial court.
Reasons
Per Ransom J. (Montgomery C.J. and Frost J. concurring):
The Court clarified that while a timely request for findings of fact and conclusions of law is not the sole method to preserve error for appellate review, the Respondent-Petitioner failed to preserve his claims. He did not timely request findings, file a motion to amend the judgment, or otherwise call the trial court's attention to the alleged insufficiency of the evidence.
The Court emphasized that appellate courts are not fact-finding bodies and depend on trial court findings to review sufficiency of evidence. Without timely objections or requests for findings, the Respondent-Petitioner waived his right to appellate review. The Court also found no exceptional circumstances warranting remand under the "ends of justice" principle.
The Court concluded that the Respondent-Petitioner’s untimely submissions and failure to preserve error precluded review, affirming the lower courts' decisions.