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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 case involves a dispute over a special warranty deed issued to the Defendant, Steve Veigel, which was declared null and void by the Plaintiff, Rabo Agrifinance, LLC. This deed, filed on July 9, 2015, conveyed real property in Quay County from three Veigel family entities to the Defendant. Prior to this conveyance, several properties, including the one at issue, were sold to the Plaintiff at a foreclosure sale on May 19, 2015. The foreclosure sale and subsequent conveyances were part of a larger litigation history involving the Veigel family and the Plaintiff, including three prior appeals and a pending fourth appeal related to the foreclosure action (paras 2-3).

Procedural History

  • Rabo Agrifinance, Inc. v. Terra XXI, Ltd., No. 34,757, mem. op. (N.M. Ct. App. Nov. 18, 2015) (non-precedential): [Not applicable or not found]
  • Rabo Agrifinance, Inc. v. Terra XXI, Ltd., 2014-NMCA-106, ¶ 2, 336 P.3d 972: [Not applicable or not found]
  • Rabo Agrifinance, Inc. v. Terra XXI, Ltd., 2012-NMCA-038, ¶ 2, 274 P.3d 127: [Not applicable or not found]
  • Rabo Agrifinance, LLC v. Terra XXI Ltd., No. A-1-CA-37117, mem. op. (N.M. Ct. App. Jan. 9, 2020) (non-precedential): [Not applicable or not found]

Parties' Submissions

  • Plaintiff: Argued that the special warranty deed issued to the Defendant should be declared null and void, as it clouded title to properties already sold to the Plaintiff in a foreclosure sale. The Plaintiff also contended that the Defendant's memorandum in opposition was untimely and that the doctrines of res judicata and collateral estoppel applied, entitling the Plaintiff to judgment as a matter of law (paras 4-6, 9).
  • Defendant: Contended that the district court abused its discretion in denying his discovery request and erred in granting summary judgment. The Defendant argued that there were genuine issues of material fact, questioned the Plaintiff's standing under the federal Farm Credit Act, and challenged the application of res judicata and collateral estoppel. The Defendant also claimed that prior court rulings were subject to collateral attack as void judgments that violated the bankruptcy court’s discharge injunction and plan confirmation (paras 7, 9).

Legal Issues

  • Whether the district court abused its discretion in denying the Defendant’s untimely discovery request (para 7).
  • Whether the district court erred in granting the Plaintiff’s motion for summary judgment, including issues related to genuine issues of material fact, standing under the federal Farm Credit Act, and the application of res judicata and collateral estoppel (para 9).

Disposition

  • The district court's orders denying discovery and granting summary judgment in favor of the Plaintiff were affirmed (para 32).

Reasons

  • The Court of Appeals held that the district court did not abuse its discretion in denying the Defendant's discovery request due to its untimeliness and overbreadth, and the Defendant's non-compliance with the pretrial order. The Court also found that the district court did not err in granting summary judgment, as the Plaintiff met its burden of demonstrating no genuine issues of material fact and was entitled to judgment as a matter of law. The Court concluded that the doctrines of res judicata and collateral estoppel were applicable, barring the Defendant from relitigating issues already decided in prior litigation. The Court reasoned that the Defendant was in privity with parties in the foreclosure case and that the cause of action in the present case was the same as in the prior litigation, thus affirming the district court's decisions (paras 7-31).
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