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, an employee of the Defendant, visited the Defendant's store on her day off to collect her paycheck. While in the store, she slipped and fell on water caused by a faulty sink drain in the bakery department, resulting in injuries to her knee, ankle, and back. She alleged that these injuries rendered her unable to work and sought damages for personal injury (para 2).
Procedural History
- District Court, September 16, 1994: A default judgment was entered in favor of the Plaintiff for $181,518.20 after the Defendant failed to file an answer to the complaint (para 3).
- District Court, September 15, 1995: The Defendant's motion to set aside the default judgment under NMRA 1-060(B)(1) and (4) was denied. The court found that it had subject matter jurisdiction, the Defendant had a meritorious defense, but the failure to file an answer was not due to excusable neglect (para 4).
Parties' Submissions
- Defendant: Argued that the default judgment was void because the district court lacked subject matter jurisdiction, as the Plaintiff's claim fell under the exclusivity provisions of the Workers' Compensation Act. Additionally, the Defendant contended that its failure to answer was due to excusable neglect and that it had a meritorious defense (paras 4, 6).
- Plaintiff: Asserted that the claim was a tort action for negligence, not a workers' compensation claim, and that the district court had jurisdiction over such matters. The Plaintiff also argued that the Defendant waived its affirmative defense by failing to file an answer (paras 6-7).
Legal Issues
- Did the district court have subject matter jurisdiction over the Plaintiff's tort claim despite the Defendant's argument that the claim was barred by the exclusivity provisions of the Workers' Compensation Act?
- Was the default judgment void due to lack of subject matter jurisdiction?
Disposition
- The Court of Appeals affirmed the district court's order denying the Defendant's motion to set aside the default judgment (para 10).
Reasons
Per Bustamante J. (Apodaca CJ. and Armijo J. concurring):
The Court held that the district court had subject matter jurisdiction over the Plaintiff's tort claim. Subject matter jurisdiction is determined by the general class of cases a court is empowered to hear, not by the specific facts of a case. The Plaintiff's complaint alleged negligence, which falls within the district court's jurisdiction as a court of general jurisdiction (paras 6-7).
The Defendant's argument that the claim was barred by the Workers' Compensation Act was deemed an affirmative defense, which must be raised in an answer. By failing to file an answer, the Defendant waived this defense. The Court also distinguished this case from others cited by the Defendant, noting that those cases involved situations where the exclusivity issue was litigated on the merits, unlike the present case (paras 7-9).
The Court concluded that the default judgment was not void and affirmed the district court's decision (paras 9-10).