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 Plaintiff, an employee of Eddy Potash, Inc., was severely injured on May 16, 1990, when she fell 66 feet from a vertical conveyor belt manlift after its top-limit switch failed to stop the device. The manlift had been installed in 1948. The Plaintiff sought damages against several corporations involved in the manlift's manufacture, sale, distribution, and installation, including the Defendant, a successor corporation to one of the original manufacturers (paras 2-3).

Procedural History

• District Court, August 9, 1993: Granted summary judgment in favor of the Defendant, holding that the Plaintiff's claims were barred by the ten-year statute of repose under NMSA 1978, Section 37-1-27 (para 4).

Parties' Submissions

• Plaintiff-Appellant: Argued that Section 37-1-27 is unconstitutional under intermediate scrutiny, as it violates her equal protection and due process rights by denying her the ability to seek redress for her injuries. She also contended that the statute was applied retroactively and that it violated the principle of foreseeability in tort law (paras 5-6, 12-13).
• Defendant-Appellee: Asserted that the Plaintiff's claims were barred by the ten-year statute of repose under Section 37-1-27, as the manlift was installed in 1948. The Defendant argued that rational basis scrutiny, not intermediate scrutiny, should apply and that the statute was constitutional. It also maintained that the statute was not applied retroactively and did not eliminate the duty of care (paras 3, 7, 10, 13).

Legal Issues

• Whether intermediate scrutiny should apply to evaluate the constitutionality of NMSA 1978, Section 37-1-27 (para 1).
• Whether Section 37-1-27 is unconstitutional under the appropriate level of scrutiny (para 1).
• Whether Section 37-1-27 applies retroactively to the Plaintiff's claims (para 1).
• Whether Section 37-1-27 violates the principle that a defendant owes a duty of care to a plaintiff if injury to the plaintiff was foreseeable (para 1).

Disposition

• The Supreme Court of New Mexico affirmed the trial court's order granting summary judgment in favor of the Defendant (para 13).

Reasons

Per Baca J. (Montgomery C.J. and Frost J. concurring):

• The Court held that rational basis scrutiny, rather than intermediate scrutiny, applies to assess the constitutionality of Section 37-1-27. The Plaintiff's interest in full recovery of damages was not implicated because she had no preexisting right to recover damages under the statute (paras 9-10).
• Applying rational basis scrutiny, the Court found Section 37-1-27 constitutional. The statute was enacted to protect those involved in construction from claims arising years after project completion, when evidence and defenses may no longer be available. This legislative objective was deemed rationally related to a legitimate governmental interest (paras 10-11).
• The Court rejected the Plaintiff's argument that Section 37-1-27 was applied retroactively, as her claims arose after the statute's enactment (para 12).
• The Court dismissed the Plaintiff's contention that the statute violated the principle of foreseeability, clarifying that the statute does not eliminate the duty of care but merely forecloses suits after ten years from substantial completion of an improvement (para 13).