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 medical malpractice case arose when a guardian ad litem for a minor entered into a settlement with a healthcare provider under the Medical Malpractice Act (MMA). The settlement included a lump sum payment for future medical expenses. The Superintendent of Insurance refused to disburse the agreed amount from the Patient’s Compensation Fund, arguing that the lump sum payment violated the MMA. The district court revoked its approval of the settlement based on the Superintendent's objections (paras 1-2).
Procedural History
- District Court, Santa Fe County: The district court initially approved the settlement agreement but later revoked its approval following the Superintendent's objections (paras 2-4).
Parties' Submissions
- Plaintiff-Appellant: Argued that the MMA does not preclude lump sum payments for future medical expenses and that the Superintendent lacks authority to object to a court-approved settlement or refuse to pay it (para 1).
- Superintendent of Insurance (Intervenor-Appellee): Contended that the MMA prohibits lump sum payments for future medical expenses and that the Superintendent has the authority to protect the Patient’s Compensation Fund by objecting to such settlements (paras 8-9).
Legal Issues
- Does the MMA prohibit lump sum payments for future medical expenses?
- Does the Superintendent of Insurance have the authority to object to a court-approved settlement under the MMA?
Disposition
- The Court of Appeals affirmed the district court's decision to revoke approval of the settlement agreement (para 24).
Reasons
Per Hanisee J. (Ives and Wray JJ. concurring in part and dissenting in part):
Hanisee J.: The MMA's Section 41-5-7(D) clearly prohibits lump sum payments for future medical expenses, as it mandates that payments be made as expenses are incurred. The Superintendent has the authority to object to settlements that violate the MMA, as they are responsible for safeguarding the Patient’s Compensation Fund (paras 8-15, 17-22).
Wray J., concurring in part and dissenting in part: Agreed that the Superintendent has authority to object to the settlement terms but disagreed with the interpretation that the plain language of Section 41-5-7(D) precludes lump sum payments. Wray J. emphasized the need to consider the broader legislative intent and the evolving statutory framework (paras 26-32).