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 Estate of Reuben Lajeuenesse, through a personal representative, initiated a wrongful death lawsuit against the Board of Regents of the University of New Mexico due to alleged negligent medical care provided by the defendants that resulted in Lajeuenesse's death.

Procedural History

• District Court of Santa Fe County: The court granted judgment as to liability as a matter of law, allowed the presentation of a video about the decedent's life over defendants' objections, and awarded damages of $750,000, which was later reduced to $400,000 plus medical charges of $13,032. The court also granted Plaintiff double costs against Defendants under Rule 1-068(A) NMRA (paras 3-4).

Parties' Submissions

• Plaintiff: Argued that the maximum liability under the Tort Claims Act (TCA) should not apply and that damages should be awarded based on the Wrongful Death Act (WDA), considering the pecuniary injury to multiple statutory beneficiaries (para 8).
• Defendants: Contended that the TCA's maximum liability of $400,000 "to any person" applies to the case, limiting the total damages the government entity could be liable for in a wrongful death action to this amount, regardless of the number of statutory beneficiaries (para 1).

Legal Issues

• Whether the TCA's maximum liability limit applies to a wrongful death action with multiple statutory beneficiaries.
• Whether the district court erred in allowing the presentation of a video about the decedent's life to the jury.
• Whether the district court erred in granting Plaintiff double costs against Defendants under Rule 1-068(A) NMRA, contrary to the TCA.

Disposition

• The Court of Appeals affirmed the judgment of the district court on all issues raised in both the appeal and the cross-appeal.

Reasons

• Per James J. Wechsler (Celia Foy Castillo, Chief Judge, and Cynthia A. Fry, Judge, concurring): The court held that the TCA prevails over the WDA in setting the maximum liability of a government entity in a wrongful death action, applying a $400,000 limit "to any person" for claims arising out of a single occurrence. The court found that the personal representative in a wrongful death action represents a single "person" for the purposes of the TCA's liability limit, regardless of the number of statutory beneficiaries (paras 1, 7-14). Regarding the video, the court determined that its probative value regarding the value of the decedent's life was not substantially outweighed by the danger of unfair prejudice, and thus, its admission was not an abuse of discretion (paras 19-26). On the issue of double costs under Rule 1-068(A) NMRA, the court found no conflict with the TCA and affirmed the district court's calculation of double costs from the date the offer of settlement was made, in accordance with the rule's language (paras 27-32).