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 a workers' compensation dispute where the claimant sought benefits in a lump sum. The case was settled in February 1990 as part of a broader settlement involving a third-party action. However, the settlement was not communicated to the Court of Appeals, which proceeded to issue an opinion on the matter in May 1990 (paras 3-4).

Procedural History

• New Mexico Department of Labor Workers' Compensation Division, February 1, 1990: Issued a "Compensation Order and Order of Approval of Lump Sum Settlement" (para 7).
• Riesenecker v. Arkansas Best Freight Systems, 110 N.M. 654, 798 P.2d 1040 (Ct. App. 1990): The Court of Appeals reversed the Workers' Compensation Division's award of lump-sum benefits in a 2-1 decision (para 3).

Parties' Submissions

• Appellant (Employer): Did not submit arguments in this decision but was involved in the earlier appeal challenging the lump-sum award (N/A in this decision).
• Appellee (Claimant): Argued that the Court of Appeals should withdraw its opinion because the case was moot at the time the opinion was issued due to the February 1990 settlement (para 6).

Legal Issues

• Should the Court of Appeals withdraw its opinion because the case was moot at the time of its issuance?
• Should the Court of Appeals vacate its judgment and remand the case to the Workers' Compensation Division for reentry of its February 1, 1990, order?
• Should the Court of Appeals publish its opinion despite the case being settled?

Disposition

• The Court of Appeals quashed its order to show cause against the attorneys for failing to notify the court of the settlement (para 15).
• The Court denied the claimant's motion to withdraw the opinion (para 15).
• The Court vacated its May 17, 1990, judgment and remanded the case to the Workers' Compensation Division for reentry of its February 1, 1990, order, effective as of that date (para 15).
• The Court ordered the publication of its opinions (para 14).

Reasons

Per Hartz J. (Minzner and Apodaca JJ. concurring):

• The Court found that neither attorney intentionally failed to notify the court of the settlement, but their conduct was unacceptable as it wasted judicial resources and prejudiced the administration of justice. The Court warned that future failures to notify would be referred to Disciplinary Counsel (paras 4-5).
• The Court determined that the case was not moot when the opinion was issued because the Workers' Compensation Division lacked jurisdiction to enter its February 1, 1990, order while the case was on appeal. The principle of appellate jurisdiction precluded the lower tribunal from acting (para 7).
• Even if the case had been moot, the Court retained discretion to decide issues of substantial public interest, such as the standards for awarding lump-sum workers' compensation benefits (para 8).
• The Court distinguished between vacating its judgment and withdrawing its opinion, concluding that vacating the judgment was appropriate to allow the Workers' Compensation Division to reenter its February 1, 1990, order. However, withdrawing the opinion was unnecessary because it had already been circulated and met the criteria for formal publication (paras 9-12).
• The Court emphasized that the publication of the opinions would assist litigants, the Workers' Compensation Division, and future appellate counsel in understanding and applying the law (paras 11-12).