This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A natural gas well explosion in the San Juan Basin on September 20, 1990, severely injured three subcontractor employees working at the site. The explosion occurred during a hazardous equipment replacement procedure, allegedly due to the failure to use a blowout preventer (BOP) and other safety measures. The well was operated by Parker & Parsley Petroleum Co. and Evergreen Resources, Inc., who were accused of negligence in their management and safety practices (paras 1-8).
Procedural History
- District Court of Bernalillo County: The jury awarded substantial compensatory damages to the plaintiffs and punitive damages against Parker. The trial court reduced the verdict by the amount of pretrial settlements with other subcontractors (headnotes, para 10).
Parties' Submissions
- Plaintiffs: Argued that the defendants were negligent in providing a safe workplace, exercising retained control over the wellsite, and complying with safety regulations. They also sought punitive damages for gross negligence (paras 9-10, 21-22).
- Defendants: Contended that the theories of negligence were unsupported by evidence, that strict liability under Saiz v. Belen School District was inapplicable, and that the plaintiffs' claims were barred by workers' compensation exclusivity. They also challenged the punitive damages award and the trial court's application of Saiz principles (paras 11, 23-25, 45-47).
Legal Issues
- Was there sufficient evidence to support the plaintiffs' negligence claims?
- Did the trial court err in applying principles of strict liability under Saiz v. Belen School District?
- Was the award of punitive damages against Parker justified?
- Did the trial court err in reducing the jury's verdict by the amount of pretrial settlements?
Disposition
- The Court of Appeals affirmed the jury's verdict and the award of punitive damages.
- The Court of Appeals reversed the trial court's reduction of the verdict by the amount of pretrial settlements (para 60).
Reasons
Per Bosson J. (Minzner J. and Pickard J. concurring):
Negligence Claims: The court found sufficient evidence to support the plaintiffs' claims of negligence, including the failure to provide a safe workplace, exercise retained control, and comply with safety regulations. The defendants' objections to the jury instructions were either unpreserved or without merit (paras 21-36).
Strict Liability under Saiz: The court held that the case was presented to the jury on negligence theories, not strict liability under Saiz. The trial court's ruling on Saiz was irrelevant to the jury's verdict, which was based on comparative fault and several liability (paras 11-20).
Punitive Damages: The court upheld the punitive damages award, finding sufficient evidence of gross negligence and reckless indifference by Parker, particularly in its failure to enforce safety measures and supervise operations. The jury instruction on gross negligence was consistent with the law at the time of trial (paras 45-55).
Reduction of Verdict: The court reversed the trial court's reduction of the verdict, holding that the principles of Saiz did not apply to the jury's negligence-based verdict. Therefore, the reduction for pretrial settlements was improper (paras 57-59).