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 claimant, an employee of Chino Mines, sought attorney's fees under the interim provisions of the Workers' Compensation Act. The claimant alleged that the employer acted in reckless disregard of his rights, resulting in economic loss. The employer contested these claims, arguing that the evidence did not support the findings of bad faith or economic loss (paras 1-2).

Procedural History

• New Mexico Department of Labor, Workers' Compensation Division: The hearing officer awarded attorney's fees to the claimant, finding that the employer acted in reckless disregard of the claimant's rights and caused economic loss.

Parties' Submissions

• Appellant (Employer): Argued that the evidence did not support the findings of reckless disregard or economic loss. Additionally, contended that the failure to submit findings and conclusions before the judgment should not preclude evidentiary review (para 1, paras 5-6).
• Respondent (Claimant): Asserted that the employer's failure to submit findings and conclusions before the judgment precluded evidentiary review. Also argued that the hearing officer erred by not addressing the issue of prejudgment interest and requested a remand for its determination (paras 1, 7).

Legal Issues

• Did the employer's failure to submit findings and conclusions before the judgment preclude evidentiary review?
• Was the hearing officer's decision regarding attorney's fees supported by evidence of reckless disregard and economic loss?
• Did the hearing officer err by failing to address the issue of prejudgment interest?

Disposition

• The Court of Appeals affirmed the hearing officer's decision to award attorney's fees to the claimant (para 9).
• The Court denied the claimant's request for a remand on the issue of prejudgment interest (para 9).
• The claimant was awarded $1,000 in attorney's fees for defending the appeal (para 9).

Reasons

Per Alarid J. (Donnelly and Apodaca JJ. concurring):

• The Court held that the employer's failure to submit findings and conclusions before the judgment precluded evidentiary review. The employer had ample opportunity to submit requests before the judgment, and nothing in the record indicated that the employer was deprived of this right (paras 4-6).
• The Court found no merit in the employer's argument that its late submission of findings and conclusions should allow for evidentiary review. The employer did not file a motion under Rule 1-052(B)(2) or any applicable statutory provisions, nor did the hearing officer take any action on the late submissions (para 6).
• On the issue of prejudgment interest, the Court determined that the hearing officer had implicitly rejected the claimant's request by not including findings on the matter and by expressly rejecting findings not adopted. The Court declined to remand the issue, as it was already decided (paras 7-8).
• The Court affirmed the hearing officer's judgment and awarded the claimant $1,000 in attorney's fees for defending the appeal (para 9).