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 case arose from an automobile accident in which the Plaintiff and his wife were injured. The Plaintiff initially offered to settle his claim for $12,000, while the Defendants countered with $4,000. The Defendants also made a separate settlement offer of $22,000 to the Plaintiff's wife. Later, the Defendants made offers of judgment under Rule 1-068 NMRA 1999, but the names on the offers were mistakenly transposed, resulting in the Plaintiff receiving an offer of $22,001 and his wife receiving an offer of $4,001. The Plaintiff accepted the offer intended for his wife. Upon realizing the error, the Defendants moved to set aside the offer (paras 2-3).

Procedural History

• District Court of Bernalillo County: The trial court granted the Defendants' motion to set aside the offer of judgment (para 1).

Parties' Submissions

• Plaintiff-Appellant: Argued that the trial court erred in granting the Defendants' motion to set aside the offer of judgment. The Plaintiff contended that Rule 1-060(B) NMRA 1999 does not apply to offers of judgment when no judgment has been entered and that the Defendants' negligence in discovering their unilateral mistake should not justify relief (para 1, para 6).
• Defendants-Appellees: Asserted that the transposition of names on the offers of judgment was a clerical error or a mistake under Rule 1-060(B), justifying the trial court's decision to set aside the offer. They argued that requiring the judgment to be entered before applying Rule 1-060(B) would prioritize form over substance (paras 4-6).

Legal Issues

• Does Rule 1-060(B) NMRA 1999 apply to the setting aside of an offer of judgment made under Rule 1-068 NMRA 1999 when no judgment has been entered?
• Did the trial court abuse its discretion in granting the Defendants' motion to set aside the offer of judgment?

Disposition

• The Court of Appeals affirmed the trial court's decision to set aside the offer of judgment (para 7).

Reasons

Per Apodaca J. (Donnelly and Bosson JJ. concurring):

• The Court held that Rule 1-060(B) applies to the setting aside of an offer of judgment under Rule 1-068, even if no judgment has been entered. The Court found the reasoning in Shelton v. Sloan, 1999-NMCA-48, persuasive, which allowed the denial of entry of judgment when grounds under Rule 1-060(B) are established (paras 4-5).
• The Court rejected the Plaintiff's reliance on Pope v. Gap, Inc., 1998-NMCA-103, noting that the context in Pope was different and did not address mistakes in offers of judgment. The Court agreed with the Defendants that requiring the judgment to be entered before applying Rule 1-060(B) would elevate form over substance (para 5).
• The Court found that the trial court did not abuse its discretion in setting aside the offer of judgment. It emphasized that trial courts have broad discretion under Rule 1-060(B) to ensure substantial justice and that the trial court's decision was neither arbitrary nor unreasonable (para 6).