This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
An employee of Patterson UTI Energy Incorporated, referred to as C.A., was injured while working at Mewbourne Oil Company's Red Hills West Unit 026H Well in Lea County, New Mexico. The incident involved removing a pipe from the well. Wesley Baker was working as an independent contractor for Mewbourne Oil Company at the time of the incident (paras 2-3).
Procedural History
- District Court, Santa Fe County: Denied Defendants' motion to compel arbitration (para 1).
Parties' Submissions
- Defendants-Appellants (Mewbourne Oil Company and Wesley Baker): Argued that the district court erred by not enforcing the Mutual Arbitration Agreement's (MAA) delegation clause and that the MAA is not unconscionable (para 1).
- Plaintiff-Appellee (Todd M. Lopez, as Guardian Ad Litem for C.A.): Asserted that Defendants waived their right to compel arbitration by missing the ten-day deadline and that the MAA is unconscionable (paras 7-9).
Legal Issues
- Did the district court err in failing to enforce the Mutual Arbitration Agreement's delegation clause?
- Is the Mutual Arbitration Agreement unconscionable?
- Did Defendants waive their right to compel arbitration by missing the ten-day deadline?
Disposition
- The New Mexico Court of Appeals reversed the district court's order and remanded with instructions to compel arbitration (para 30).
Reasons
Per Bogardus J. (Baca J. concurring):
- The court found that the delegation clause in the MAA was clear and unmistakable evidence of the parties' agreement to arbitrate gateway issues, and Defendants did not waive their right to invoke it (paras 18-23).
- The court concluded that the district court erred by considering the unconscionability of the MAA without a specific challenge to the delegation clause (paras 24-28).
- The court determined that the proper forum for Plaintiff's claims is arbitration, as the parties had agreed to arbitrate questions of arbitrability (para 29).
Yohalem J., dissenting:
- Yohalem J. argued that the district court's decision should be affirmed based on Rule 1-007.2, which sets a mandatory time limit for filing a motion to compel arbitration. The Defendants' lack of knowledge of the MAA did not constitute "excusable neglect" under Rule 1-006(B)(1)(b) (paras 32-49).
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