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 arose from a fatal car accident in Bernalillo County, New Mexico, leading to a wrongful death action. The plaintiffs, residents of Bernalillo County, sued twenty-one defendants, including a New Mexico corporation (the only resident defendant) and twenty foreign corporations, one of which had a registered agent in Santa Fe County (paras 2-3).

Procedural History

• District Court: Denied the resident defendant's motion to dismiss for improper venue (para 3).
• Court of Appeals: Denied the resident defendant's application for interlocutory appeal (para 3).

Parties' Submissions

• Plaintiff-Respondent: Argued that venue was proper in Santa Fe County because one of the foreign corporations had a registered agent there, and the venue statute allows venue for one defendant to establish venue for all (paras 2-3, 9).
• Defendant-Petitioner: Contended that venue was improper in Santa Fe County, asserting that the venue statute does not permit a foreign corporation's statutory agent to establish venue for a resident defendant (paras 3, 5).

Legal Issues

• Whether venue for a resident defendant can be established in the county where a foreign corporation's statutory agent resides (para 1).

Disposition

• The Supreme Court of New Mexico affirmed the district court's denial of the motion to dismiss for improper venue (para 17).

Reasons

Per Bosson J. (Chávez CJ., Maes J., and Vigil J. concurring):

• The Court interpreted the New Mexico venue statute, specifically Subsections A and F, to determine whether venue for a resident defendant could be based on the location of a foreign corporation's statutory agent (paras 1, 8-10).
• Subsection A allows venue for one defendant to establish venue for all, while Subsection F limits venue for foreign corporations with statutory agents to specific counties. The Court reconciled these provisions, holding that Subsection F does not restrict the application of Subsection A to resident defendants (paras 10-12).
• The Court reasoned that foreign corporations with statutory agents "reside" in New Mexico for venue purposes, aligning with legislative intent to treat such corporations similarly to resident defendants (paras 11-12).
• The Court distinguished this case from its prior decision in Baker v. BP America Production Company, which involved only foreign corporations, and emphasized that the "good for one, good for all" rule applies to resident defendants when venue is based on a foreign corporation's statutory agent (paras 6-8, 13).
• The Court acknowledged that this interpretation might appear to favor foreign defendants but found it consistent with the statute's text, policy goals, and longstanding practice (paras 15-16).
• The Court concluded that venue for the resident defendant was proper in Santa Fe County, where the foreign corporation's statutory agent resided (para 17).