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 consumed L-Tryptophan (LT) tablets, a dietary supplement manufactured by the Defendant, from June to November 1989. She began experiencing symptoms such as flu-like conditions, fatigue, memory loss, nausea, and a rash. Suspecting the tablets as the cause, she stopped taking them in November 1989. Over the years, she consulted multiple physicians, some of whom linked her symptoms to LT, while others diagnosed her with lupus. In 1996, testing revealed contamination in the LT tablets, leading the Plaintiff to file a lawsuit against the Defendant, alleging injuries caused by a defective product (paras 2-10).
Procedural History
- District Court, May 28, 1997: Denied the Defendant's motion for summary judgment, finding a material factual issue regarding the statute of limitations (para 11).
Parties' Submissions
- Defendant: Argued that the Plaintiff's claims were time-barred under the statute of limitations. They contended that the discovery rule should not apply to product liability cases and that the Plaintiff had sufficient information in 1990 to connect her symptoms to LT, triggering the statute of limitations (paras 12, 20-25).
- Plaintiff: Asserted that the discovery rule applied, delaying the statute of limitations until she reasonably knew the cause of her injuries. She argued that despite her suspicions in 1989, she lacked definitive medical evidence linking LT to her symptoms until 1996 (paras 13, 20-21).
Legal Issues
- Does the discovery rule apply to product liability cases in New Mexico?
- If the discovery rule applies, when did the Plaintiff know or reasonably should have known the cause of her injuries, thereby triggering the statute of limitations?
Disposition
- The Court of Appeals reversed the District Court's denial of summary judgment and remanded the case with instructions to dismiss the Plaintiff's complaint (para 26).
Reasons
Per Donnelly J. (Wechsler and Bustamante JJ. concurring):
The Court held that the discovery rule applies to product liability cases in New Mexico, allowing the statute of limitations to commence when a plaintiff knows or reasonably should know of the injury and its cause (paras 19-20). However, the Court found that the Plaintiff had sufficient information by 1990 to connect her symptoms to LT. This included her own suspicions, advice from family, media reports, and medical opinions linking LT to her condition (paras 22-23). The Court emphasized that the discovery rule does not toll the statute of limitations merely because of conflicting medical opinions or the absence of definitive proof (paras 24-25). Consequently, the Plaintiff's claims, filed in 1996, were time-barred under the three-year statute of limitations (para 25).