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

A gas explosion occurred at the Thunderbird Lodge in Taos Ski Valley in 1992, injuring the Plaintiffs. The explosion was caused by leaking propane gas from a line servicing a neighboring business, Terry Sports, Inc. The propane line was improperly exposed above ground, contrary to industry regulations and New Mexico law. The Plaintiffs alleged negligence and breach of warranty against several defendants, including the supplier of the propane, Petrolane Gas Services, and other entities involved in the supply chain of the propane and its odorizing agent (paras 2-3).

Procedural History

• District Court of Taos County: The trial court ruled in favor of the Defendants, finding no negligence or product defect. The Plaintiffs' motion for a new trial was denied (paras 1, 8).

Parties' Submissions

• Plaintiffs: Argued that the trial court erred by (1) informing the jury about settlements with other defendants, which they claimed was prejudicial, and (2) instructing the jury to consider the fault of Suburban Propane, a nonparty not listed in the pretrial order. They contended that these errors influenced the jury's verdict (paras 1, 8-9, 22-23).
• Defendants: Asserted that the trial court acted within its discretion in informing the jury about the settlements to avoid confusion and that the instruction regarding Suburban Propane's fault was supported by evidence presented at trial (paras 10, 22-23).

Legal Issues

• Was it an abuse of discretion for the trial court to inform the jury about settlements with other defendants?
• Did the trial court err in instructing the jury to consider the fault of Suburban Propane, a nonparty not listed in the pretrial order?

Disposition

• The Supreme Court of New Mexico affirmed the trial court's judgment, holding that the disclosure of settlements was not an abuse of discretion and that the error in instructing the jury on Suburban Propane's fault was harmless (paras 1, 33-34).

Reasons

Per Minzner J. (Ransom and McKinnon JJ. concurring):

• Disclosure of Settlements: The trial court acted within its discretion in informing the jury about the settlements to prevent confusion. Rule 11-408 NMRA 1996 does not categorically prohibit such disclosures if they serve a valid purpose, such as clarifying the jury's responsibilities. The Plaintiffs failed to demonstrate prejudice or propose alternative instructions to mitigate potential confusion (paras 10-21).

• Instruction on Suburban Propane's Fault: The trial court erred in allowing the jury to consider Suburban Propane's fault because the issue was not raised in the pretrial order, and the Plaintiffs lacked sufficient notice. However, the error was deemed harmless because the jury found no negligence on the part of the named defendants, making the instruction on Suburban Propane irrelevant to the outcome (paras 22-32).