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 sustained personal injuries, including a closed-head injury, in a motor vehicle accident. These injuries allegedly caused memory and cognitive difficulties, psychiatric problems, and lost earnings. The Defendant sought to challenge the Plaintiff's claims by referencing a prior workers' compensation claim and other medical history, including a near-drowning incident 18 years earlier that caused temporary cognitive issues (paras 2-3).
Procedural History
- District Court of Bernalillo County: The jury returned a verdict in favor of the Plaintiff, awarding damages for personal injuries sustained in the motor vehicle accident.
Parties' Submissions
- Defendant-Appellant: Argued that the trial court erred by (1) denying a continuance to depose a psychologist, (2) excluding the Plaintiff's workers' compensation complaint as evidence, and (3) giving a non-Uniform Jury Instruction that was allegedly misleading and contradictory (para 1).
- Plaintiff-Appellee: Defended the trial court's decisions, asserting that the Defendant was not prejudiced by the denial of the continuance, the exclusion of the workers' compensation complaint was proper, and the jury instructions were appropriate and complementary (paras 6-16).
Legal Issues
- Was the Defendant denied a fair trial due to the trial court's refusal to grant a continuance to depose a psychologist?
- Did the trial court abuse its discretion by excluding the Plaintiff's workers' compensation complaint from evidence?
- Did the trial court err in giving a non-Uniform Jury Instruction, and was it contradictory to another instruction?
Disposition
- The Court of Appeals affirmed the trial court's judgment in favor of the Plaintiff (para 17).
Reasons
Per Apodaca J. (Minzner and Pickard JJ. concurring):
Denial of Continuance: The trial court did not abuse its discretion in denying the Defendant's request for a continuance. The Defendant had prior knowledge of the Plaintiff's earlier industrial injury and treating physicians but failed to adequately investigate. The Defendant also did not sufficiently follow up on the trial court's suggestion to depose the psychologist during the trial. Generalized claims of prejudice were insufficient to demonstrate error (paras 6-11).
Exclusion of Workers' Compensation Complaint: The trial court properly excluded the workers' compensation complaint under Rule 11-403 due to its potential to confuse the jury. The complaint's reference to "total disability" under workers' compensation law was narrower than the damages claimed in this case and could have misled the jury. The trial court's decision to exclude the evidence was within its discretion (paras 12-13).
Non-Uniform Jury Instruction: The Defendant failed to preserve its objection to the non-Uniform Jury Instruction, as it did not raise specific arguments about contradictions or Rule 1-051(D) findings at trial. Even if preserved, the instructions were complementary rather than contradictory. The McGinnis instruction addressed the Defendant's burden to prove future employment opportunities, while UJI 13-1811 addressed the Plaintiff's duty to mitigate damages. The trial court did not err in giving both instructions (paras 14-16).