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

• The personal representative of Esther Collado's wrongful death estate sued Fiesta Park Healthcare, LLC, Enchanted Health Development, LLC, and WW Management, LLC, alleging negligence in Mrs. Collado's care. Mrs. Collado, aged 88, was admitted to the Medical Resort at Fiesta Park following hip surgery and developed deep tissue injuries on her heels, leading to her death two years later (paras 4-5).

Procedural History

• District Court of Bernalillo County: Jury found Defendants negligent and engaged in a joint venture, allocating percentages of negligence to each. Post-trial, the court granted Defendants' motion for judgment as a matter of law (JMOL) on the joint venture claim, amending the judgment to eliminate joint and several liability but maintaining individual liability findings (paras 1-3).

Parties' Submissions

• Plaintiff-Appellee/Cross-Appellant: Argued that the district court erred in granting the motion for JMOL on the joint venture claim (para 3).
• Defendants-Appellants/Cross-Appellees: Contended that the district court erred in not ordering a new trial after granting JMOL and challenged the admission of expert testimony and the evidence supporting the jury’s verdict on individual liability and causation (para 3).

Legal Issues

• Whether the district court properly granted the posttrial JMOL on the joint venture claim.
• Whether the district court afforded Defendants the proper remedy after granting JMOL.
• Whether the evidence supported the jury’s verdict that found Enchanted and WWM individually liable for a portion of the fault.
• Whether evidence supporting causation was admissible and sufficient (para 7).

Disposition

• The Court of Appeals reversed the district court’s order granting the JMOL on the joint venture claim, affirmed all other aspects of the district court’s rulings, and remanded for entry of judgment reflecting the jury’s verdict (para 3).

Reasons

• The Court of Appeals found that the evidence supported the jury’s verdict on the joint venture, individual liability of Enchanted and WWM, and causation. The court emphasized that the jury could reasonably conclude from the evidence that the defendants agreed to mutual ownership and control, and to share resources to operate the facility for profit. The court also held that expert testimony on causation was admissible and sufficient to support the jury’s verdict, rejecting Defendants' arguments that the expert's opinions were unreliable or insufficiently tied to the facts of the case (paras 8-42).