AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• Third-Party Plaintiff Terry A. Brawley was severely injured in an accident while riding his all-terrain vehicle (ATV) after drinking at a bar. He sought coverage under a health plan provided by his wife’s employer, New Mexico Institute of Mining and Technology (NM Tech), which was denied on the grounds that his injuries were sustained while under the influence of alcohol, thus excluded from coverage under the health plan's terms (paras 1-2).

Procedural History

• District Court of Bernalillo County, Alan M. Malott, District Judge: Found NM Tech had breached its statutory duty to properly investigate the claims but also found Brawley’s injuries were not covered by the health plan due to alcohol influence being "a cause" of the accident (para 1).

Parties' Submissions

• Defendants/Third-Party Plaintiffs/Appellants: Argued that the district court and NM Tech erred in relying on a certain blood alcohol content report and that his claims should be covered under the "concurrent cause" or "independent intervening cause" doctrines (para 1).
• Third-Party Defendant/Appellee (NM Tech): Contended that the denial of benefits was appropriate because there was sufficient evidence that the accident bore a "direct relationship" to Brawley’s "ingestion of alcohol" and was otherwise supported by sufficient evidence (para 8).

Legal Issues

• Whether the district court erred in admitting Exhibit B as evidence that Brawley was under the influence of alcohol at the time of the accident (para 10).
• Whether, even if alcohol use and resultant impairment was a cause of the accident as found by the district court, the district court erred in its application of the law of causation in insurance cases (para 9).

Disposition

• The Court of Appeals affirmed the district court's decision, concluding that Brawley’s evidentiary arguments do not present reversible error and that Brawley failed to preserve his arguments as to causation (para 1).

Reasons

• The Court of Appeals, per Judge Michael D. Bustamante, with Judges Jonathan B. Sutin and Timothy L. Garcia concurring, held that the district court's admission of Exhibit B was not reversible error because the applicability of the alcohol exclusion does not depend on a certain blood alcohol level but rather on whether the insured was under the influence of alcohol at the time of the accident. The court found that other evidence supported the district court’s implicit finding that Brawley was under the influence of alcohol at the time of the accident (paras 12-14). Furthermore, the court concluded that the Brawleys' arguments regarding concurrent causation and independent intervening cause were not preserved for appeal as they were not adequately presented to the district court nor were rulings on these theories elicited (paras 23-24).