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 purchased a house from the Defendant, who allegedly misrepresented the adequacy of the property's water well. After discovering the well was inadequate, the Plaintiffs sued for misrepresentation and professional negligence, claiming the house was worth $69,560.02 less than it would have been with a proper well. Following the trial, the Plaintiffs sold the house for a price significantly higher than the value estimated at trial (paras 2-3).
Procedural History
- District Court, July 26, 1989: Judgment entered in favor of the Plaintiffs based on the jury's verdict that the house was worth $69,560.02 less due to the inadequate well (para 2).
- District Court, October 20, 1989: The Defendant filed a motion to set aside the judgment, citing newly discovered evidence that the Plaintiffs sold the house for a higher price than estimated at trial. The District Court granted the motion and ordered a new trial (para 2).
Parties' Submissions
- Plaintiffs-Appellants: Argued that the District Court erred in granting a new trial because the evidence relied upon by the Defendant concerned events that occurred after the trial, which should not qualify as "newly discovered evidence" under Rule 1-060(B)(2) (paras 1, 3).
- Defendant-Appellee: Contended that the post-trial sale of the house constituted newly discovered evidence that demonstrated the Plaintiffs had suffered no damages. Additionally, on appeal, the Defendant attempted to argue fraud under Rule 1-060(B)(3) and sought to rely on Rule 1-060(B)(6) as an alternative basis for relief (paras 2, 4).
Legal Issues
- Whether post-trial events can qualify as "newly discovered evidence" under Rule 1-060(B)(2) (para 5).
- Whether the Defendant could rely on Rule 1-060(B)(3) or Rule 1-060(B)(6) to justify setting aside the judgment (para 4).
Disposition
- The Court of Appeals reversed the District Court's decision to grant a new trial and directed the reinstatement of the original judgment in favor of the Plaintiffs (paras 1, 15).
Reasons
Per Hartz J. (Bivins and Apodaca JJ. concurring):
The Court held that post-trial events, such as the sale of the house, do not qualify as "newly discovered evidence" under Rule 1-060(B)(2) because such evidence must have existed at the time of trial. Allowing post-trial events to undermine trial predictions would lead to endless litigation and undermine the finality of judgments (paras 5-6, 12-14).
The Court rejected the Defendant's reliance on Rule 1-060(B)(3) because fraud was neither pleaded nor proven in the District Court. Similarly, Rule 1-060(B)(6) could not be used as a fallback when the requirements of Rule 1-060(B)(2) were not met, as it is limited to reasons not addressed in the other clauses of the rule (para 4).
The Court emphasized that damages based on expert predictions inherently involve uncertainty, and parties accept the risk of inaccuracy at trial. Public policy favors finality in litigation, and post-trial events that merely challenge the accuracy of trial predictions do not justify reopening judgments (paras 12-14).