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

A minor, born in 1990, developed a seizure disorder in 1991 and was treated with phenobarbital in 1992. After discontinuing the medication at the Defendant's hospital, the minor suffered a grand mal seizure in 1993, resulting in severe brain damage and disabilities. The Plaintiff, acting as the minor's guardian, filed a lawsuit in 1999, seeking damages for the injuries allegedly caused by the Defendant's actions (para 2).

Procedural History

• District Court, Bernalillo County: The Defendant's motion to dismiss was granted on the basis that the Plaintiff failed to comply with the statute of limitations (para 2).

Parties' Submissions

• Plaintiff-Appellant: Argued that the statute of limitations under the Tort Claims Act should not bar the claim because the minor was incapable of meeting the statutory deadline due to age and disability (paras 1, 9-10).
• Defendant-Appellee: Contended that the claim was time-barred under Section 41-4-15(A) of the Tort Claims Act, which provides a two-year limitation period with an extension until the minor's ninth birthday (paras 3, 9).
• Amicus Curiae (New Mexico Trial Lawyers Association): Supported the Plaintiff's position, emphasizing the due process implications for minors (para 10).
• Amicus Curiae (New Mexico Defense Lawyers Association): Supported the Defendant's position, arguing for the application of the statutory deadline (para 10).

Legal Issues

• Does the statute of limitations under Section 41-4-15(A) of the Tort Claims Act violate due process when applied to a minor incapable of meeting the statutory deadline?

Disposition

• The Court of Appeals reversed the trial court's dismissal and remanded the case for further proceedings (para 11).

Reasons

Per Pickard J. (Wechsler and Fry JJ. concurring):

• The Court held that the reasoning in prior cases, such as Tafoya v. Doe and Rider v. Albuquerque Public Schools, which invalidated the 90-day notice provision for minors incapable of compliance, also applied to the statute of limitations in this case (paras 1, 6).
• The Court emphasized that due process protections for minors focus on whether it is reasonable to expect a child in the injured minor's circumstances to meet statutory deadlines. The minor in this case, severely disabled at age two, could not reasonably be expected to comply with the statute of limitations (paras 7, 9).
• The Defendant failed to present any evidence suggesting that the minor or someone acting on his behalf could have met the statutory deadline. The Court found no factual basis to distinguish this case from the principles established in Rider (paras 9-10).
• The Court rejected the Defendant's reliance on Jaramillo v. State, distinguishing it on the grounds that it did not involve the special disability of being a minor (para 8).
• The Court concluded that applying the statutory deadline to bar the minor's claim would violate due process, as the minor was incapable of meeting the deadline without specific legal or factual support to the contrary (paras 9-10).