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Facts

  • The case involves Mabry Construction, Inc., and other plaintiffs appealing a district court's decision that it did not have personal jurisdiction over the defendant, Oasis Management Resources, LLC (OMR), leading to an order of dismissal. The plaintiffs filed a motion to reconsider this decision, supported by newly discovered evidence they argued showed the court did have jurisdiction over OMR.

Procedural History

  • District Court of Santa Fe County, April 20, 2012: Order granting OMR's motion to dismiss for lack of personal jurisdiction over OMR.

Parties' Submissions

  • Plaintiffs: Argued that newly discovered evidence demonstrated the district court had personal jurisdiction over OMR. They contended that the court could consider any grounds justifying correction of the order, not limited to fraud, and that the evidence was "newly discovered" as it was not produced in response to discovery requests.
  • Defendant (OMR): Argued that the court was limited to considering the motion under the specific ground of fraud as initially stated by the plaintiffs and that the new evidence did not qualify as "newly discovered" under the applicable rules.

Legal Issues

  • Whether the district court erred in denying the plaintiffs' motion to reconsider the dismissal of OMR for lack of personal jurisdiction based on newly discovered evidence.
  • Whether the motion to reconsider should have been considered under Rule 1-059(E) instead of Rule 1-060(B).

Disposition

  • The order of the district court denying Mabry’s motion to reconsider is reversed, and the case is remanded for further proceedings consistent with the opinion.

Reasons

  • Vigil, J., with Sutin, J., and Vanzi, J., concurring, found that the district court incorrectly considered the plaintiffs' motion to reconsider under Rule 1-060(B) when it should have been considered under Rule 1-059(E) due to the timing of the motion's filing. The court emphasized that the nomenclature of the motion is not controlling and that motions filed within ten days of a judgment should be treated as motions to alter or amend the judgment under Rule 1-059(E). The appellate court concluded that the district court had considerable discretion to reconsider its judgment under Rule 1-059(E) and that there was no abuse of discretion in considering new material as part of a motion for reconsideration as long as the delay in presenting the new material was not for strategic reasons and its relevance outweighed any prejudice. The appellate court did not address the merits of whether the district court has personal jurisdiction over OMR, as the resolution of this question depends on the district court’s resolution of the motion to reconsider upon remand (paras 1-13).
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