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 rented ski equipment from the Defendant's business in Santa Fe County. She alleged that the Defendant negligently mis-set the binding releases on the skis, which caused her to sustain personal injuries during a skiing accident. The rental contract was executed, performed, and the accident occurred in Santa Fe County. The Plaintiff resided in Santa Fe County but filed the lawsuit in Bernalillo County without alleging venue (paras 1-2).

Procedural History

• District Court, Bernalillo County: Denied the Defendant's motion to dismiss for improper venue, ruling that the Defendant waived the objection by not raising it in its answer. The court later granted the Defendant's motion to transfer the case to Santa Fe County based on forum non conveniens (para 2).
• District Court, Santa Fe County: The case was tried, and the jury returned a verdict in favor of the Defendant on the Plaintiff's personal injury claim and against the Plaintiff on the Defendant's counterclaim (para 2).

Parties' Submissions

• Plaintiff-Appellant: Argued that the transfer of venue to Santa Fe County was improper under the Supreme Court's later decision in First Financial Trust Co. v. Scott, which held that intrastate forum non conveniens transfers are not permitted. She sought retroactive application of Scott to invalidate the transfer and judgment. She also claimed relief under Rule 1-060(B)(4) and (6), asserting that the judgment was void and that substantial justice required relief (paras 3-4, 16-17).
• Defendant-Appellee: Contended that the transfer was proper under the then-prevailing precedent (State ex rel. Southern Pacific Transportation Co. v. Frost). The Defendant argued that retroactive application of Scott would be inequitable due to reliance on prior law and the resources expended in the trial. The Defendant also alleged that the Plaintiff intentionally failed to allege venue in her complaint, violating procedural rules (paras 3, 11, 18).

Legal Issues

• Was the judgment void due to the retroactive application of First Financial Trust Co. v. Scott to prohibit the transfer of venue?
• Should the Plaintiff be granted relief from the judgment under Rule 1-060(B)(4) or (6)?

Disposition

• The Supreme Court of New Mexico affirmed the denial of the Plaintiff's motion for relief from judgment (para 4).

Reasons

Per McKinnon J. (Franchini C.J., Baca, Minzner, and Serna JJ. concurring):

• The Court held that the judgment was not void because the transfer of venue was proper under the then-prevailing precedent (Frost). The trial court had jurisdiction and provided due process, and Scott could not be applied retroactively to invalidate the transfer (paras 4-5, 16).
• Applying the Beavers framework and the Chevron Oil factors, the Court found that retroactive application of Scott was unwarranted. The decision in Scott overruled clear precedent, and both the Defendant and the trial court relied on Frost. Retroactive application would undermine the legislative intent behind the venue statute and result in inequitable outcomes, as the case had already been tried in the proper forum (paras 7-15).
• The Plaintiff's Rule 1-060(B)(4) claim failed because the judgment was not void. Her Rule 1-060(B)(6) claim was also denied, as there were no exceptional circumstances warranting equitable relief. The Court noted that the Plaintiff sought to exploit the Defendant's waiver of venue objections and failed to demonstrate that the trial was unfair or unjust (paras 16-18).