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, California residents, filed a personal injury lawsuit in Santa Fe County, New Mexico, following an oilfield accident in San Juan County. The injury was allegedly caused by a defective drilling rig manufactured by nine foreign corporations that were not registered to do business in New Mexico and lacked statutory agents in the state. The Plaintiffs also sued BP America Production Company (BP), the operator of the well, alleging liability under the theory of ultra-hazardous or inherently dangerous activity. BP is a foreign corporation registered to do business in New Mexico and maintains a statutory agent in Lea County (paras 2-3).
Procedural History
- District Court: Denied BP's motion to dismiss for improper venue, holding that venue was proper in Santa Fe County for all defendants, including BP, based on the precedent set in Toscano v. Lovato, 2002-NMCA-022 (para 4).
- Court of Appeals: Declined to accept interlocutory appeal of the district court's ruling (para 4).
Parties' Submissions
- Defendant (BP): Argued that venue in Santa Fe County was improper under New Mexico's venue statute, as BP maintains a statutory agent in Lea County, and the accident occurred in San Juan County. BP contended that venue should be limited to either Lea County or San Juan County (paras 3, 12).
- Plaintiffs: Asserted that venue in Santa Fe County was proper because the Manufacturing Defendants, as foreign corporations without statutory agents, could be sued in any county in New Mexico. They argued that once venue was proper for the Manufacturing Defendants, it was also proper for BP, relying on the precedent set in Toscano v. Lovato (paras 4, 9).
Legal Issues
- Whether venue for a foreign corporation without a statutory agent in New Mexico can establish venue for a foreign corporation with a statutory agent in a different county (para 5).
- Whether the precedent set in Toscano v. Lovato should be overruled (paras 12-13).
Disposition
- The Supreme Court of New Mexico reversed the district court's ruling, holding that venue in Santa Fe County was improper for BP (para 20).
- The Court overruled the relevant portion of Toscano v. Lovato that allowed venue for one defendant to establish venue for all defendants, regardless of statutory venue limitations (para 19).
Reasons
Per Bosson CJ (Minzner, Serna, Maes, and Chávez JJ. concurring):
The Court conducted a de novo review of the venue statute and emphasized the legislative intent to balance the convenience of litigants and judicial efficiency. The Court found that the venue statute provides distinct rules for foreign corporations with and without statutory agents. Under Section 38-3-1(F), foreign corporations with statutory agents can only be sued in specific counties: the county of the plaintiff's residence, the county where the statutory agent resides, or the county where the cause of action originated. The Court rejected the Plaintiffs' reliance on Toscano v. Lovato, finding that its broad interpretation of the venue statute was inconsistent with legislative intent and improperly allowed plaintiffs to circumvent statutory venue limitations (paras 6-14, 18).
The Court clarified that venue for a foreign corporation without a statutory agent cannot establish venue for a foreign corporation with a statutory agent. It held that BP, as a foreign corporation with a statutory agent in Lea County, could only be sued in Lea County or San Juan County, where the accident occurred. The Court also overruled the portion of Toscano that allowed venue for one defendant to establish venue for all defendants, as it undermined the statutory framework and led to results contrary to legislative intent (paras 14-19).