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 Plaintiffs, insured under a title insurance policy issued by the Defendant, disputed the Defendant's compliance with its obligations under the policy. The policy included a mandatory arbitration clause, which the Defendant invoked to resolve the dispute. The Plaintiffs challenged the enforceability of the arbitration clause, arguing it violated their constitutional right to a jury trial and conflicted with statutory provisions allowing judicial resolution of their claims (paras 1, 3-4).

Procedural History

• District Court, December 9, 1999: Denied the Plaintiffs' motion for a preliminary injunction to prevent arbitration and stayed the court proceedings pending arbitration (para 5).
• District Court, January 20, 2000: Stayed arbitration pending appeal (para 5).

Parties' Submissions

• Plaintiffs-Appellants: Argued that the mandatory arbitration clause violated their constitutional right to a jury trial for common-law claims and conflicted with statutory provisions granting a right to judicial resolution of statutory claims (paras 1, 4-5).
• Defendants-Appellees: Contended that the Plaintiffs contractually waived their right to a judicial resolution by agreeing to a policy containing an arbitration clause and that the State could mandate arbitration under its police powers (paras 7, 9).

Legal Issues

• Does the mandatory arbitration clause in the title insurance policy violate the Plaintiffs' constitutional right to a jury trial for common-law claims?
• Does the arbitration clause conflict with statutory provisions granting a right to judicial resolution of statutory claims?

Disposition

• The Court of Appeals reversed the trial court's order referring the dispute to arbitration and remanded the case for further proceedings (para 12).

Reasons

Per A. Joseph Alarid J. (Bustamante and Fry JJ. concurring):

• The Court held that the Plaintiffs did not voluntarily consent to arbitration because the arbitration clause was imposed by state regulation, making it a non-consensual submission (para 7).
• The Court found that mandatory arbitration of the Plaintiffs' common-law claims violated their constitutional right to a jury trial under Article II, Section 12 of the New Mexico Constitution, as these claims were traditionally triable to a jury during the territorial period (paras 8-10).
• Regarding the statutory claims, the Court determined that the arbitration clause conflicted with specific statutory provisions granting a right to judicial resolution in district court. The Legislature's designation of courts as the proper forum for these claims prevailed over the regulation mandating arbitration (para 11).
• The Court ordered the trial court to stay arbitration and denied the Plaintiffs' request for attorney's fees on appeal without prejudice, allowing them to seek fees in the trial court if they prevail on a cause of action with a right to such fees (para 12).