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

• On February 2, 1980, a riot began at the New Mexico State Penitentiary. Governor Bruce King called in the New Mexico National Guard, including the Plaintiffs, to address the situation. Over thirty-two years later, the Plaintiffs filed a lawsuit alleging they suffered from work-related post-traumatic stress disorder (PTSD) or exacerbation of pre-existing PTSD due to their deployment during the riot. They sought relief under the Workers’ Compensation Act applicable at the time of the riot and alternatively under Delgado v. Phelps Dodge Chino, Inc. (para 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiffs-Appellants: Argued that they were employees of the State of New Mexico through the Department of Military Affairs in 1980 and suffered from PTSD as a result of their deployment during the 1980 riot. They contended their workers' compensation claims should be governed by the Workers’ Compensation Act in effect at the time of the riot and alternatively sought relief under Delgado v. Phelps Dodge Chino, Inc. (para 3).
• Defendants-Appellees: Moved for summary judgment, arguing that Plaintiffs could not meet the requirements of either the old or new Workers’ Compensation Act, that their claims were time-barred, and that Delgado did not apply because there was no evidence of Defendants deploying Plaintiffs with the expectation and intention that they would be injured (para 4).

Legal Issues

• Whether the district court had jurisdiction over Plaintiffs’ workers' compensation claims (para 5).
• Whether the district court properly granted summary judgment on Plaintiffs’ Delgado claims and if the Workers’ Compensation Act provides their exclusive remedy (para 9).

Disposition

• The district court's order granting summary judgment in favor of Defendants on both the workers' compensation claims and the claims made pursuant to Delgado v. Phelps Dodge Chino, Inc. was affirmed, except for the part concerning the jurisdiction over workers' compensation claims, which was remanded to the district court to dismiss those claims for lack of jurisdiction (para 1, 8, 20).

Reasons

• The Court of Appeals found that the district court did not have jurisdiction over the workers' compensation claims because they were filed after December 1, 1986, when jurisdiction for such claims had been transferred to the workers' compensation administration. The Court also held that the Plaintiffs failed to demonstrate the existence of specific evidentiary facts that would require a trial on the merits of their Delgado claims. The Court concluded that the Plaintiffs did not meet the high threshold of culpability established in Delgado and failed to show that the Workers’ Compensation Act does not provide their exclusive remedy. Additionally, the Court did not address Plaintiffs' arguments regarding the Tort Claims Act, as they had not demonstrated an exception to the exclusivity provisions of the Workers’ Compensation Act. Lastly, the Court dismissed Quintana's arguments regarding the district court's handling of requests for admission and the exclusion of his proffered exhibit list due to either acknowledgment of the admissions or inadequate briefing (paras 5-19).