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 Plaintiffs purchased a house in Farmington, New Mexico, and later filed a lawsuit alleging breach of contract related to the purchase. Over a four-year period, all judges in the Eleventh Judicial District either recused themselves or were excused from the case due to conflicts of interest or other reasons (paras 2-3).

Procedural History

• District Court, 2000: Plaintiffs filed the lawsuit in the Eleventh Judicial District Court, San Juan County, alleging breach of contract (para 2).
• District Court, Date Unspecified: The Chief Justice of the New Mexico Supreme Court designated Judge Carol Vigil from the First Judicial District to preside over the case after all Eleventh Judicial District judges were removed (para 3).
• District Court, Date Unspecified: Judge Vigil retired, and Judge Daniel Sanchez of the First Judicial District was assigned to the case. Judge Sanchez granted the Plaintiffs’ motion for a change of venue to the First Judicial District (paras 4-5).
• Court of Appeals, Date Unspecified: The Court of Appeals denied Defendants’ application for an interlocutory appeal of the change of venue order (para 6).

Parties' Submissions

• Plaintiffs: Argued that under NMSA 1978, Section 38-3-3(A), and Section 38-3-7, the recusal of Eleventh Judicial District judges required a change of venue to the First Judicial District. They contended that a judge’s conflict of interest disqualified not only the judge but also the entire judicial district (paras 4, 10).
• Defendants: Asserted that Section 38-3-3(A) only required a change of venue when the presiding judge had a conflict of interest. They argued that the statute did not mandate disqualification of an entire judicial district (para 10).

Legal Issues

• Whether NMSA 1978, Section 38-3-3(A), requires a change of venue when all judges in a judicial district are recused or excused.
• Whether the district court abused its discretion in granting the Plaintiffs’ motion for a change of venue.

Disposition

• The Supreme Court of New Mexico reversed the change of venue and remanded the case to the Eleventh Judicial District Court, with Judge Sanchez presiding (para 24).

Reasons

Per Maes J. (Chávez CJ., Serna, Bosson, and Daniels JJ. concurring):

• The Court analyzed the historical context of Section 38-3-3(A), which was enacted during a time when judicial districts in New Mexico had only one judge. The statute was intended to address conflicts of interest in single-judge districts, but its relevance has diminished with the expansion of the judiciary and the adoption of modern rules governing judicial recusal and venue (paras 14-22).
• The Court found that interpreting Section 38-3-3(A) to disqualify an entire judicial district based on a single judge’s conflict of interest would lead to undesirable results, such as forum shopping and undermining judicial discretion (paras 11-12).
• The Court held that Section 38-3-3(A) is now without force or effect, as its purpose has been supplanted by constitutional provisions and rules such as Rule 1-088(B) NMRA, which provide alternative remedies for judicial conflicts of interest (paras 18-22).
• The district court’s decision to grant the change of venue was based solely on Section 38-3-3(A), rendering the decision an abuse of discretion (para 23).