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 alleged that the Defendant sexually abused her in 1991 when she was nine years old. The Plaintiff was born in December 1981 and filed her lawsuit in 2001, shortly after her nineteenth birthday. The case centered on whether the applicable statute of limitations barred her claim (paras 1, 3).

Procedural History

• District Court, Taos County: The court held that the Plaintiff's claim was not barred under NMSA 1978, § 37-1-30(A)(1), which extended the statute of limitations for childhood sexual abuse claims to the Plaintiff's twenty-fourth birthday. The court rejected the Plaintiff's argument under § 37-1-30(A)(2) but allowed the claim to proceed under § 37-1-30(A)(1) (paras 5-6).

Parties' Submissions

• Defendant: Argued that the Plaintiff's claim was barred under the statutes of limitations in effect at the time of the abuse, specifically NMSA 1978, §§ 37-1-8 and 37-1-10, which required filing by the Plaintiff's nineteenth birthday (paras 3, 7).
• Plaintiff: Contended that her claim was timely under NMSA 1978, § 37-1-30, which extended the filing deadline to her twenty-fourth birthday. She also argued that § 37-1-30(A)(2) applied because her psychological injuries were not discovered until after the abuse (paras 3-4, 7).

Legal Issues

• Does NMSA 1978, § 37-1-30(A)(1), which extends the statute of limitations for childhood sexual abuse claims, apply retroactively to conduct that occurred before its enactment?
• Was the Plaintiff's claim barred under the statutes of limitations in effect at the time of the abuse?

Disposition

• The Court of Appeals held that NMSA 1978, § 37-1-30(A)(1) applied to the Plaintiff's claim, and her action was not barred. The decision of the district court was affirmed (paras 21-22).

Reasons

Per Sutin J. (Pickard and Castillo JJ. concurring):

• The Court determined that statutes of limitations are generally procedural and apply to actions filed after their enactment unless they affect substantive rights or vested interests (paras 10-11, 16).
• The Court found that § 37-1-30(A)(1) did not attach new legal consequences to past events and was procedural in nature. Therefore, it applied to the Plaintiff's claim, which was filed after the statute's enactment but before her twenty-fourth birthday (paras 18-21).
• The Court rejected the Defendant's argument that the prior statutes of limitations (§§ 37-1-8 and 37-1-10) barred the claim, as § 37-1-30(A)(1) extended the filing period (paras 7, 21).
• The Court declined to address the Plaintiff's argument under § 37-1-30(A)(2), as the claim was resolved under § 37-1-30(A)(1) (para 7).