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 Plaintiff filed a lawsuit against the Defendant, a business operating as a Subway store, alleging negligence. The Plaintiff sought to present evidence of negligence per se, including a violation of the building code, to establish liability. The jury ultimately found the Defendant negligent but determined that the Defendant's negligence was not the proximate cause of the Plaintiff's injuries.
Procedural History
- District Court of Bernalillo County: The jury returned a verdict in favor of the Defendant, finding that the Defendant's negligence was not the proximate cause of the Plaintiff's injuries.
Parties' Submissions
- Plaintiff-Appellant: Argued that the district court erred in excluding evidence of negligence per se, specifically a violation of the building code, which could have influenced the jury's decision on liability and causation.
- Defendant-Appellee: Contended that the exclusion of the building code evidence was harmless error because the jury already found negligence, and the evidence would not have changed the finding on proximate causation.
Legal Issues
- Was the exclusion of evidence of negligence per se, specifically a violation of the building code, a prejudicial error requiring a new trial?
Disposition
- The Court of Appeals affirmed the district court's decision, holding that the exclusion of the building code evidence was harmless error.
Reasons
Per Bustamante J. (Castillo and Vigil JJ. concurring):
The Court reasoned that the exclusion of evidence of negligence per se was harmless because the jury had already found the Defendant negligent based on other evidence. The violation of the building code would not have addressed the issue of proximate causation, which the jury found lacking. The Court relied on precedent, including Britton v. Boulden and Lovato v. Crawford & Co., to support the principle that an error is harmless if it would not have changed the jury's decision. The Court concluded that the Plaintiff was not prejudiced by the exclusion of the building code evidence and affirmed the district court's judgment.