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

• In 2008, Erin Burnworth and Leroy Gutierrez cosigned a student loan contract with Citizens Bank to finance Burnworth's undergraduate education. They chose a "Full Deferral" repayment option, deferring payment until Burnworth finished school or five-and-a-half years had passed since the loan's disbursement date. The loan's repayment date was initially set for July 15, 2011, but was changed twice due to Burnworth's extended enrollment, ultimately being set for December 9, 2014. Neither Burnworth nor Gutierrez began repaying the loan on the new repayment date (paras 2-3).

Procedural History

• District Court of Roosevelt County: Dismissed Citizens Bank's consumer debt action against Burnworth and Gutierrez based on the statute of limitations having run under either NMSA 1978, Section 37-1-3(A) (2015) or NMSA 1978, Section 37-1-4 (1880) (para 1).

Parties' Submissions

• Citizens Bank: Argued that the six-year statute of limitations applies to this contractual dispute, the district court erred in holding that the doctrine of merger applied, and a written agreement was not required to modify the payment date in the disclosure statement (para 1).
• Defendants-Appellees: Argued that the claim fell outside the six-year statute of limitations, citing the original repayment date in the disclosure statement. They also contended that any modification to the agreement must be jointly agreed upon and in writing, and no such writing exists (paras 4-5).

Legal Issues

• Whether the six-year statute of limitations applies to this contractual dispute.
• Whether the district court erred in holding that the doctrine of merger applied.
• Whether a written agreement was required to modify the payment date in the disclosure statement.

Disposition

• The Court of Appeals reversed the district court's dismissal and remanded for further proceedings (para 20).

Reasons

• The Court of Appeals found that the district court erred as a matter of law when it applied the doctrine of merger to interpret the terms of the credit agreement and disclosure statement. The court held that the documents should be read and construed together, as the credit agreement incorporates the disclosure statement by reference. The court also noted that applying the doctrine of merger would violate the federal Truth in Lending Act (TILA), which requires lenders to make certain disclosures to borrowers. The court concluded that the district court's finding of the repayment date being July 15, 2011, was incorrect and that Citizens Bank's claim, filed in August 2018 for payments due beginning December 9, 2014, was timely under either the six-year or four-year statute of limitations. The court did not address the remaining issues due to its decision on the doctrine of merger (paras 7-20).