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 case concerns a dispute over retirement benefits under the Public Employees Retirement Association (PERA). A member of PERA elected a payment option that required spousal consent, which was not obtained. After the member's death, the surviving spouse claimed benefits under a different payment option and challenged PERA's attempt to recover overpayments made during the member's lifetime (paras 2-4).

Procedural History

• PERA Board, October 28, 1998: Granted the surviving spouse benefits under a specific payment option and limited PERA's recovery of overpayments to one year (para 4).
• District Court, August 25, 1999: Denied PERA's motion for summary judgment and upheld the PERA Board's decision (para 5).
• Court of Appeals, 2001-NMCA-076: Reversed the district court, holding that the statute limiting PERA's recovery to one year was unconstitutional (para 6).

Parties' Submissions

• Defendant (Surviving Spouse): Argued that the statute limiting PERA's recovery to one year was constitutional as it acted as a statute of repose, barring the remedy of recovery without extinguishing the obligation (para 9).
• Plaintiff (PERA): Contended that the statute was unconstitutional under Article IV, Section 32 of the New Mexico Constitution, as it diminished the state's ability to recover overpayments (para 7).

Legal Issues

• Does Section 10-11-4.2(A) of the New Mexico Statutes violate Article IV, Section 32 of the New Mexico Constitution by limiting the state's recovery of overpayments to one year? (para 7)

Disposition

• The Supreme Court of New Mexico reversed the Court of Appeals' decision, holding that Section 10-11-4.2(A) is a constitutional statute of repose (para 1).

Reasons

Per Kennedy J. (Serna C.J., Franchini, Minzner, and Maes JJ. concurring):

The Court held that Section 10-11-4.2(A) is a valid statute of repose, as it bars the remedy of recovery after one year but does not extinguish the underlying obligation. The statute was found to act prospectively, providing PERA with a reasonable period to recover overpayments while promoting fairness to beneficiaries. The Court emphasized that the legislature has the authority to enact statutes of repose applicable to the state, provided they do not violate constitutional prohibitions (paras 9, 19-24).

The Court also clarified that Article IV, Section 32 prohibits the release or diminishment of fixed obligations owed to the state but does not preclude the legislature from enacting statutes that limit remedies for contingent or prospective obligations. The statute's purpose of reducing hardship for beneficiaries and incentivizing PERA to conduct timely audits was deemed consistent with legislative intent (paras 15-16, 26).