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 driver and his minor son were involved in a fatal automobile accident after the driver’s vehicle, towing a utility trailer loaded with mulch, hit a bump, causing the trailer to fishtail and the vehicle to roll over. The driver was ejected and died instantly, while the son sustained minor injuries. The estate of the deceased driver sued the company that loaded the mulch, alleging negligence in the loading process (paras 2-4).
Procedural History
- District Court of Sandoval County: The jury awarded $1,780,200 in damages, apportioning 70% liability to the Defendant and 30% to the deceased driver. The Defendant appealed, challenging evidentiary rulings and jury instructions (headnotes, para 1).
Parties' Submissions
- Defendant-Appellant: Argued that the district court erred by excluding evidence of the driver’s failure to wear a seat belt, refusing certain jury instructions, and excluding relevant evidence, including expert testimony and a jury view of the trailer (para 1, paras 25-39).
- Plaintiff-Appellee: Contended that the exclusion of seat belt evidence was consistent with New Mexico law, the jury instructions were proper, and the evidentiary rulings were within the court’s discretion (paras 10-11, paras 25-39).
Legal Issues
- Whether the district court erred in excluding evidence of the driver’s failure to wear a seat belt (para 1).
- Whether the district court erred in refusing the Defendant’s requested jury instructions (para 1).
- Whether the district court erred in excluding certain evidence, including expert testimony and a jury view of the trailer (para 1).
Disposition
- The Court of Appeals affirmed the district court’s rulings (para 40).
Reasons
Per Black J. (Bosson and Bustamante JJ. concurring):
Exclusion of Seat Belt Evidence: The court upheld the exclusion of seat belt evidence, citing New Mexico law (Section 66-7-373), which prohibits the use of seat belt non-use to establish fault, negligence, or to limit or apportion damages. The court rejected the Defendant’s constitutional challenges, finding no violation of due process, separation of powers, or Article IV, Section 34 of the New Mexico Constitution (paras 6-24).
Jury Instructions: The court found no error in the district court’s refusal to give the Defendant’s requested instructions on strict liability, negligence per se, and the loading of the mulch. The strict liability theory was not pleaded or tried by consent, and there was insufficient evidence to support the negligence per se instruction. The instruction on the loading of the mulch was properly excluded due to its nonsensical wording (paras 25-31).
Evidentiary Rulings: The court held that the district court acted within its discretion in excluding expert testimony on driver inattention, comparisons of vehicle owner manuals, and a jury view of the trailer. The expert testimony was deemed unnecessary for the jury, the comparison of manuals lacked proper foundation, and the trailer’s condition at trial was not shown to be substantially similar to its condition at the time of the accident (paras 32-39).