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Facts

  • Maria Garza, the Plaintiff, sought to reopen a case against the City of Roswell and its City Manager, the Defendants, claiming breach of the original final judgment filed on August 18, 1999, which had not resulted in her reinstatement to her former position. This action followed the execution and filing of a satisfaction and release of judgment on May 3, 2002, where Plaintiff released all claims against Defendants for a sum of $132,165.20. Nearly nine years later, Plaintiff filed a petition to reopen the case, alongside motions for contempt, to compel, and to withdraw the satisfaction of judgment and release of all claims, alleging Defendants' failure to comply with the 1999 final judgment.

Procedural History

  • District Court of Chaves County, August 18, 1999: Entered a final judgment.
  • Court of Appeals of New Mexico, Post-August 18, 1999: Defendants filed an appeal leading to an amended final judgment on September 26, 2001.
  • District Court of Chaves County, March 11, 2011: Plaintiff filed a petition to reopen the case, claiming breach of the 1999 final judgment.

Parties' Submissions

  • Plaintiff: Argued that Defendants breached the original final judgment by failing to reinstate her to her former position, contended the satisfaction of judgment was unconstitutional and deprived her of her rights, and claimed she was forced to sign the satisfaction of judgment under duress.
  • Defendants: Responded by highlighting the execution of the satisfaction of judgment on May 3, 2002, which they argued precluded Plaintiff from seeking further relief. Defendants also requested attorney fees and costs for having to respond to Plaintiff's petition to reopen.

Legal Issues

  • Whether the district court erred in denying Plaintiff's motion to preclude defense counsel from ex parte communications.
  • Whether the district court erred in denying Plaintiff's motion to withdraw the satisfaction of judgment and release of all claims due to alleged breach.
  • Whether the district court erred in rendering Plaintiff's motion to compel and motion for contempt moot.

Disposition

  • The district court's orders denying Plaintiff's motions to preclude defense counsel from ex parte communications, to withdraw the satisfaction of judgment, for contempt, and to compel were affirmed.

Reasons

  • The Court of Appeals, per Judge Timothy L. Garcia, with Judges Jonathan B. Sutin and Roderick T. Kennedy concurring, found no persuasive facts or authorities in Plaintiff's second memorandum to overturn the district court's decisions. The court held that the satisfaction of judgment superseded the final judgment, thereby satisfying all terms and conditions and precluding any breach by Defendants. The court also determined there was no factual basis for voiding the satisfaction of judgment on grounds of fraud or duress, as Plaintiff had chosen to receive a lump sum payment instead of reinstatement. Furthermore, the court affirmed the district court's finding of no ex parte communications by Defendants' counsel.
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