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 early 2013, the University Village Mobile Home Park LLC (Landlord) initiated legal action to terminate the tenancy of John Calderon and Margaret Parks (Tenants) under the Mobile Home Park Act, alleging disturbances caused by Tenant Parks’ nephews. The dispute led to a mediation and a settlement agreement in May 2013, allowing Tenants to remain under conditions including a prohibition on the nephews' presence on the property and a requirement for no reported incidents or activities after 10 p.m. Despite compliance notifications, the Landlord later served a notice to quit, claiming the nephews had violated the park's rules by entering the premises, leading to a second petition to terminate tenancy (paras 2-3).

Procedural History

• Metropolitan Court: Judgment of eviction against Tenants for allegedly breaching the settlement agreement by allowing the nephews onto the property.
• District Court of Bernalillo County: Affirmed the metropolitan court's judgment, agreeing that Tenants had the obligation to prevent the nephews from entering the property and had violated this obligation (para 6).

Parties' Submissions

• Landlord: Argued that the settlement agreement was an amendment to the park rules or rental agreement, and its violation by Tenants constituted good cause for tenancy termination under the Mobile Home Park Act. Claimed that the presence of the nephews on the property was a breach of the agreement (para 8).
• Tenants: Contended that the reasons provided for their eviction did not demonstrate good cause for termination under the Mobile Home Park Act. Asserted that they had complied with the settlement agreement by notifying the nephews they were not allowed on the property and that any presence of the nephews was without their consent (paras 7-8).

Legal Issues

• Whether the settlement agreement imposed an obligation on Tenants to ensure the nephews did not enter the mobile home park property.
• Whether Tenants breached the settlement agreement, justifying eviction under the Mobile Home Park Act.

Disposition

• The Court of Appeals of New Mexico reversed the district court’s decision, finding no substantial evidence that Tenants violated the settlement agreement (para 17).

Reasons

• Per Julie J. Vargas, J. (Jonathan B. Sutin, J., and Michael E. Vigil, J., concurring):
  The settlement agreement did not explicitly obligate Tenants to prevent the nephews from entering the park property. The agreement only required notification to the nephews that they were not allowed on the property, which was complied with by both parties (paras 12-13).
  The presence of the nephews on the property, as described, did not constitute a reported "incident" under the terms of the settlement agreement. The term "incident" was interpreted to refer to disruptive behavior, which was not evidenced in the described encounter (paras 14-16).
  The Court concluded that Tenants did not breach the settlement agreement as they had no obligation to ensure the nephews did not come onto the property, and the brief encounter with a nephew did not qualify as an "incident" warranting eviction (paras 13, 16).