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 graduate teaching assistant at the University of New Mexico (UNM) was injured by an electric shock while attempting to repair a machine in a photography darkroom. The assistant had been compensated for her work with monthly payments and a tuition waiver. Following the injury, she received medical care paid for by UNM and filed workers' compensation forms. Later, she sought workers' compensation benefits and also filed a personal injury lawsuit against UNM's Board of Regents (paras 2-4).
Procedural History
- Workers' Compensation Administration, March 9, 1998: The workers' compensation judge concluded that the Workers' Compensation Act provided the exclusive remedy for the worker's injury and that she was estopped from pursuing a personal injury claim (para 3).
- District Court, January 7, 1998: The district court granted summary judgment in favor of the Board of Regents, applying the doctrine of collateral estoppel to dismiss the worker's personal injury lawsuit (para 4).
Parties' Submissions
- Appellant (Worker): Argued that she was not covered by the Workers' Compensation Act because she was a student laborer and that UNM, as an educational institution, was exempt from the Act. She also contended that she did not knowingly elect workers' compensation as her sole remedy and that the district court erred in applying collateral estoppel (paras 5-6).
- Appellee (UNM and Board of Regents): Asserted that the Workers' Compensation Act applied to the worker, that UNM had elected to waive its exemption under the Act, and that the worker's exclusive remedy was workers' compensation. They also argued that collateral estoppel barred the personal injury lawsuit (paras 3-4, 6).
Legal Issues
- Does the Workers' Compensation Act apply to the worker, and is it her exclusive remedy?
- Does Section 52-1-63 of the Workers' Compensation Act exempt the worker or UNM from the Act's coverage?
- Did the district court err in applying collateral estoppel to dismiss the worker's personal injury lawsuit?
Disposition
- The Court of Appeals affirmed the workers' compensation judge's Compensation Order and the district court's summary judgment order (paras 6, 17-18).
Reasons
Per Bustamante J. (Apodaca and Wechsler JJ. concurring):
- The court held that Section 52-1-63 of the Workers' Compensation Act exempts educational institutions, not student workers, from the Act's coverage. The exemption is a privilege that institutions may waive, and UNM had elected to waive its exemption and comply with the Act (paras 7-15).
- The court found that the Workers' Compensation Act applied to the worker, making it her exclusive remedy. The worker was estopped from pursuing a personal injury claim because she had accepted workers' compensation benefits (paras 3, 15-16).
- Since the Compensation Order was affirmed, the district court's application of collateral estoppel to dismiss the personal injury lawsuit was also upheld (paras 6, 17-18).
You are being directed to the most recent version of the statute which may not be the version considered at the time of the judgment.