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 visited the Defendant's apartment complex to search for a residence for her parents. While leaving the premises, she misstepped, fell, and suffered a severe ankle fracture. She subsequently filed a negligence claim against the Defendant, alleging that the Defendant's actions or omissions caused her injury (para 2).

Procedural History

• District Court of Bernalillo County: The jury returned a verdict in favor of the Defendant, finding no negligence. The Plaintiff's motion for a new trial was denied (paras 1-2).

Parties' Submissions

• Plaintiff-Appellant: Argued that the bailiff's improper communication with the jury during deliberations constituted extraneous prejudicial information and violated the open court rule, warranting a new trial. The Plaintiff also submitted juror affidavits to support her claims (paras 1, 5-6, 15-16, 24-25).
• Defendant-Appellee: Contended that the bailiff's communication was not substantive and did not prejudice the jury. The Defendant argued that the presumption of prejudice was rebutted and that the jury's verdict should stand (paras 17, 21-22, 26).

Legal Issues

• Did the bailiff's communication with the jury during deliberations constitute extraneous prejudicial information?
• Did the bailiff's actions violate the open court rule?
• Was the presumption of prejudice rebutted by the Defendant?

Disposition

• The Court of Appeals reversed the trial court's decision and ordered a new trial (paras 6, 28-29).

Reasons

Per Alarid CJ (Hartz and Chavez JJ. concurring):

• The Court found that the bailiff's statement to the jury, which incorrectly asserted that it was too late to submit a question to the judge, constituted extraneous prejudicial information. This misstatement of law improperly influenced the jury's deliberations and created a presumption of prejudice (paras 16-17, 21).
• The Court held that the presumption of prejudice was not rebutted by the Defendant. The bailiff's communication plausibly stifled further jury discussion and clarification of the disputed issues, which could have affected the verdict (paras 21-23).
• The Court also determined that the bailiff's refusal to submit the jury's question to the judge violated the open court rule, which requires all communications between the jury and the court to occur in open court and in the presence of the parties. This violation further supported the presumption of prejudice (paras 24-27).
• The trial court's denial of the Plaintiff's motion for a new trial was deemed an abuse of discretion, as the unauthorized communication and its prejudicial effects warranted a new trial (paras 28-29).