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, an administrator at Western New Mexico University, sued the Defendant, a professor at the same university, for defamation. The case arose from alleged defamatory statements made by the Defendant that the Plaintiff claimed caused injury to her reputation. The jury found that the Plaintiff had been defamed but awarded her zero dollars in damages (paras 2-3).
Procedural History
- District Court, Grant County: The jury found in favor of the Plaintiff on the issue of defamation but awarded her zero dollars in damages. The trial court denied the Defendant's motion for judgment notwithstanding the verdict and awarded the Plaintiff $1,620.10 in costs (paras 3, 14).
Parties' Submissions
- Defendant-Appellant: Argued that the jury's verdict, which awarded zero damages, was effectively a verdict in his favor. He contended that the Plaintiff failed to prove damages and that the trial court erred in denying his motion for judgment notwithstanding the verdict (paras 1, 4).
- Plaintiff-Appellee: Asserted that the jury's finding of defamation constituted a legal and moral victory, even without a monetary damages award. She argued that the trial court correctly upheld the jury's verdict and awarded her costs (paras 6, 14).
Legal Issues
- Whether a jury verdict finding defamation but awarding zero damages constitutes a verdict for the Defendant as a matter of law (para 1).
- Whether the trial court erred in denying the Defendant's motion for judgment notwithstanding the verdict and awarding costs to the Plaintiff (para 1).
Disposition
- The Court of Appeals affirmed the trial court's decision, holding that the jury's verdict was in favor of the Plaintiff and not inconsistent, and that the trial court did not err in awarding costs to the Plaintiff (para 14).
Reasons
Per Apodaca J. (Alarid and Chavez JJ. concurring):
The Court held that under New Mexico's uniform jury instructions for defamation cases, the jury follows a two-step process: first, determining liability, and second, assessing damages. The instructions do not require the Plaintiff to prove monetary damages, only actual injury to her reputation (paras 5-6). The jury's verdict, which found the Defendant liable but awarded zero damages, was not inconsistent or contradictory. The Court interpreted the zero-dollar award as a symbolic gesture indicating nominal damages, reflecting a moral and legal victory for the Plaintiff (paras 6-7).
The Court distinguished this case from prior New Mexico cases, such as Marr v. Nagel and Callaway v. Olguin, which involved ambiguous or procedurally distinct verdicts. It also declined to follow out-of-jurisdiction cases cited by the Defendant, noting differences in jury instructions and procedural contexts (paras 8-13).
The Court concluded that the trial court properly denied the Defendant's motion for judgment notwithstanding the verdict and correctly awarded costs to the Plaintiff, as she was the prevailing party under the jury's verdict (para 14).