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

• Kuckelman Pump Service-Acculectric, Inc. (Kuckelman) initiated a lien foreclosure and breach of contract action against Hacienda del Cerezo, Ltd. (Hacienda) for unpaid work on Hacienda’s water well. Hacienda countered with claims against Kuckelman for violations of the Unfair Trade Practices Act (UPA), fraud, and unjust enrichment, alleging misrepresentations regarding the value of salvaged materials and the quality of work performed in both 1995 and 2009.

Procedural History

• District Court of Santa Fe County, Barbara J. Vigil, District Judge: Directed verdict against Hacienda on its counterclaims, denied Hacienda’s motion to amend scheduling order deadlines, awarded Kuckelman attorney fees for defending a motion to compel and for the suit, and awarded Kuckelman prejudgment interest at an 18% annual rate.

Parties' Submissions

• Plaintiff-Appellee (Kuckelman): Argued for lien foreclosure and breach of contract for unpaid work on Hacienda’s water well.
• Defendants-Appellants (Hacienda): Asserted counterclaims against Kuckelman for violations of the UPA, fraud, and unjust enrichment related to misrepresentations about the value of salvaged materials and the quality of work performed.

Legal Issues

• Whether the district court erred in directing a verdict against Hacienda on its counterclaims.
• Whether the district court properly denied Hacienda’s motion to amend the scheduling order deadlines.
• Whether the district court was correct in awarding Kuckelman attorney fees incurred in defending a motion to compel and for the suit.
• Whether the district court erred in awarding Kuckelman prejudgment interest at an 18% annual rate.

Disposition

• Affirmed the district court’s decisions on the first four issues.
• Reversed and remanded the decision on the prejudgment interest to determine the proper amount pursuant to NMSA 1978, Section 56-8-3.
• Granted Kuckelman’s request for attorney fees incurred on appeal and remanded for determination of the proper amount.

Reasons

• The Court of Appeals found that Hacienda did not present sufficient evidence to support its counterclaims of UPA violations, fraud, or negligence. The court upheld the district court’s denial of Hacienda’s motion to amend scheduling order deadlines, citing Hacienda’s delay and the district court’s discretion in managing its docket. The award of attorney fees to Kuckelman for defending Hacienda’s motion to compel and for the suit was deemed appropriate under the circumstances, including the need to respond to Hacienda’s litigation actions. However, the court agreed with Hacienda that the district court improperly applied Section 56-8-4 for prejudgment interest, which applies only to postjudgment interest, and remanded for a determination of prejudgment interest under the correct statute, Section 56-8-3. Kuckelman’s request for attorney fees on appeal was granted due to its status as the prevailing party in the lien action dispute (paras 1-42).