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 case involves a wrongful death and negligence suit filed by Erin Pearson, the personal representative of James Sanderson's wrongful death estate, against Genesis Healthcare entities and Karen Jenkins, following Mr. Sanderson's death during his stay at Bear Canyon Rehabilitation Center. As part of Mr. Sanderson's admission paperwork, Pearson signed a Voluntary Binding Arbitration Agreement on his behalf. The defendants sought to enforce this agreement and compel arbitration, which was denied by the district court (paras 1-2).

Procedural History

• District Court of Bernalillo County: Denied Defendants' motion to compel arbitration and, alternatively, to compel discovery (para 1).

Parties' Submissions

• Defendants: Argued that the district court erred by refusing to enforce the Voluntary Binding Arbitration Agreement and by denying their motion to compel discovery related to Plaintiff’s authority to sign the Agreement on behalf of Mr. Sanderson (para 1).
• Plaintiff: Contended that she had no authority to bind Mr. Sanderson to the Agreement and specifically challenged the delegation clause as unconscionable (para 5).

Legal Issues

• Whether the district court erred in refusing to enforce the Voluntary Binding Arbitration Agreement signed by the Plaintiff on behalf of Mr. Sanderson (para 3).
• Whether the district court erred in denying Defendants' motion to compel discovery on the Agreement (para 18).

Disposition

• The New Mexico Court of Appeals affirmed the district court's denial of Defendants' motion to compel arbitration and, alternatively, to compel discovery (paras 22-23).

Reasons

• The Court of Appeals, per Judge Kristina Bogardus, with Judges J. Miles Hanisee and Jane B. Yohalem concurring, held that:
  The district court did not err in refusing to enforce the Agreement, finding that Defendants failed to meet their burden of establishing that Plaintiff had authority to bind Mr. Sanderson to the Agreement. The court applied general principles of contract interpretation and agency law, concluding that Defendants did not prove Plaintiff had actual or apparent authority to sign the Agreement on Mr. Sanderson's behalf (paras 3-14).
  The district court did not err in concluding Plaintiff lacked authority to bind Mr. Sanderson to the Arbitration Agreement, as Defendants did not establish Mr. Sanderson’s incapacity, which was required to trigger the power of attorney that would have granted Plaintiff the authority to sign the Agreement (paras 9-14).
  The district court did not err in denying Defendants' motion to compel discovery, as Defendants had ample opportunity to conduct discovery and failed to do so. The court noted that Defendants did not request discovery from Plaintiff nor moved for a continuance to conduct or compel discovery before filing their motion to compel arbitration (paras 18-21).