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 alleged that in 1977, during a medical examination required for high school sports eligibility, the Defendant, a doctor, sexually abused him by masturbating him under the guise of a prostate exam. The Plaintiff did not claim to have repressed the memory of the incident but argued that he only understood the psychological impact of the abuse years later through therapy (paras 2-5).

Procedural History

• District Court of Bernalillo County: Denied the Defendants' motions for summary judgment, finding that genuine issues of material fact remained regarding when the Plaintiff knew or should have known of the connection between the alleged abuse and his injury.

Parties' Submissions

• Defendants (Appellants): Argued that the Plaintiff's claim was barred by the three-year statute of limitations under NMSA 1978, § 37-1-30(A)(2), asserting that the Plaintiff knew or should have known of the abuse and its impact well before the limitations cutoff date (paras 6, 14).
• Plaintiff (Appellee): Contended that he did not fully understand the psychological impact of the abuse until after February 5, 1994, as supported by his therapist's testimony, making the claim timely under the statute (paras 6, 15).

Legal Issues

• Whether the trial court erred in denying summary judgment by finding that genuine issues of material fact existed regarding when the Plaintiff knew or had reason to know of the connection between the alleged abuse and his injury under NMSA 1978, § 37-1-30(A)(2).
• Whether the statute of limitations under NMSA 1978, § 37-1-30(A)(2) requires competent medical or psychological testimony to establish when a Plaintiff knew or had reason to know of the connection between the abuse and the injury.

Disposition

• The Court of Appeals affirmed the trial court's denial of summary judgment and remanded the case for trial on the statute of limitations issue and, if timely, on the merits (paras 22-23).

Reasons

Per Wechsler J. (Pickard CJ and Apodaca J. concurring):

• The Court interpreted NMSA 1978, § 37-1-30(A)(2) to require competent medical or psychological testimony to establish both when the Plaintiff knew or had reason to know of the abuse and when the Plaintiff understood its connection to the injury (paras 10-13).
• The Court rejected the Defendants' argument that the statute of limitations began to run when the Plaintiff had some cognitive awareness of the abuse and its effects, emphasizing that the statute requires expert testimony to determine when the Plaintiff understood the causal connection (paras 12-15).
• The Court distinguished this case from Martinez-Sandoval v. Kirsch, noting that the latter involved physical injuries and a general statute of limitations, whereas this case concerns psychological injuries and a specialized statute (paras 16-18).
• The Court found that the therapist's testimony supported differing inferences about when the Plaintiff understood the impact of the abuse, making summary judgment inappropriate. The question of when the Plaintiff knew or had reason to know of the connection is a factual issue for the jury (paras 19-20).
• The Court clarified that the statute does not require a Plaintiff to fully understand every aspect of their injury but does require sufficient expert testimony to establish when the Plaintiff understood the connection between the abuse and the injury (para 21).