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 plaintiffs brought a claim against the defendant, alleging prima facie torts. The dispute centered on whether the plaintiffs needed to explicitly state that the defendant's actions were "malicious" to establish a prima facie tort claim. The plaintiffs argued that the necessary elements of the claim were adequately pleaded in their complaint.
Procedural History
- Court of Appeals: The Court of Appeals ruled against the plaintiffs, finding either that they lacked standing to bring the prima facie tort claims or that the claims lacked merit as a matter of law.
Parties' Submissions
- Plaintiffs: Argued that their complaint sufficiently pleaded the elements of a prima facie tort, including any requirement of malice, as outlined in the uniform jury instruction (SCRA 1986, 13-1631). They contended that the necessary averments were included in paragraphs 67 through 72 of their first amended complaint. (N/A)
- Defendant: Asserted that the plaintiffs' claims were deficient because they failed to explicitly allege that the defendant's actions were "malicious," and further argued that the plaintiffs either lacked standing or that the claims were without merit under the facts pleaded.
Legal Issues
- Must a complaint for prima facie tort explicitly allege that the defendant's actions were "malicious" to state a valid claim?
- Did the plaintiffs lack standing to bring prima facie tort claims, or were the claims without merit as a matter of law?
Disposition
- The Supreme Court of New Mexico granted the petition for writ of certiorari, holding that the plaintiffs' complaint did not need to explicitly allege "malicious" conduct to state a prima facie tort claim. The case was remanded to the Court of Appeals to address the issues of standing and the merits of the claims.
Reasons
Per the Supreme Court of New Mexico:
The Court concluded that the plaintiffs' complaint adequately pleaded the elements of a prima facie tort as outlined in the uniform jury instruction (SCRA 1986, 13-1631). The Court noted that if malice is an element of prima facie tort—a question it did not decide—such an element was sufficiently averred in the complaint. The Court identified paragraphs 67 through 72 of the first amended complaint as containing the necessary averments.
The Court remanded the case to the Court of Appeals to determine whether the plaintiffs lacked standing to bring the claims or whether the claims were without merit as a matter of law based on the facts pleaded.