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, through her parents, filed a medical malpractice suit against nine healthcare providers and entities involved in her prenatal care and delivery. The plaintiff alleged that various acts of negligence during the pregnancy and delivery caused her severe disabilities, leaving her functioning at the level of a one- to three-month-old child at the age of ten (paras 3-4).
Procedural History
- District Court, March 8, 1994: The jury returned a verdict in favor of all defendants. The plaintiff's motion for a new trial was denied, and the court ordered all parties to bear their own costs (paras 1, 4).
Parties' Submissions
- Plaintiff: Argued that the trial court abused its discretion by granting defendants twenty peremptory challenges, denying the plaintiff additional challenges, and refusing a new trial based on juror misconduct. The plaintiff also contended that the rule governing peremptory challenges violated equal protection rights (para 1).
- Defendants: In their cross-appeal, three groups of defendants argued that the trial court abused its discretion by denying their motions for an award of costs. They also defended the allocation of peremptory challenges and opposed the plaintiff's claims of juror misconduct (para 1).
Legal Issues
- Did the trial court abuse its discretion in granting twenty peremptory challenges to the defendants and denying additional challenges to the plaintiff?
- Does the rule governing peremptory challenges violate the plaintiff's equal protection rights?
- Did the trial court err in refusing to grant a new trial based on alleged juror misconduct?
- Did the trial court abuse its discretion in denying the defendants' motions for costs?
Disposition
- The trial court's judgment was affirmed on all issues (para 2).
Reasons
Per Apodaca J. (Alarid and Flores JJ. concurring):
Peremptory Challenges: The trial court did not abuse its discretion in granting twenty peremptory challenges to the defendants, as their interests were sufficiently diverse. The rule governing peremptory challenges does not authorize "equalization" of challenges between plaintiffs and defendants, and it does not violate equal protection rights. Peremptory challenges are not a fundamental right, and the rule's classification based on the diversity of interests is rationally related to a legitimate state interest (paras 6-18).
Juror Misconduct: The trial court did not err in denying a new trial. The alleged communication between a juror and an alternate juror concerned only the timing of the verdict and did not involve the merits of the case. There was no evidence of prejudice or improper influence on the jury's decision (paras 19-22).
Costs: The trial court acted within its discretion in denying the defendants' motions for costs. The court properly considered the plaintiff's financial hardship and the equitable circumstances of the case. The plaintiff's claims were not frivolous, and there was no evidence of bad faith or abusive litigation tactics (paras 23-31).