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 2005, a daughter was born to a couple who were not married. The father acknowledged paternity but only provided child support in 2011 and 2012. The mother assigned her right to child support to the State due to the assistance provided to her child. In 2016, the Child Support Enforcement Division (CSED) filed a petition seeking child and medical support from the father (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Respondent-Appellant (Father): Argued that the New Mexico Uniform Parentage Act’s (NMUPA) retroactive child support provision does not apply to him because he acknowledged paternity before the petition for child support was filed (para 5).
• Petitioners-Appellees (Mother and CSED): Sought child and medical support from Father, arguing that the NMUPA applied and authorized an order of support retroactive to the date of the couple’s separation (paras 3-4).

Legal Issues

• Whether the NMUPA’s retroactive child support provision applies to a father who acknowledged paternity before a petition for child support was filed (para 1).

Disposition

• The district court’s decision to order the father to pay retroactive child support was affirmed (para 34).

Reasons

• The Court, led by Judge Ives, with Judges Hanisee and Medina concurring, held that the NMUPA’s retroactive support provision applies to the father despite his prior acknowledgment of paternity. The Court reasoned that an unchallenged acknowledgment of paternity is equivalent to an adjudication of paternity under the NMUPA, thus authorizing the court to order child support, including retroactively. The Court rejected the father’s interpretation that an acknowledgment of paternity executed before a petition for support is filed should exempt him from the NMUPA remedy of retroactive support. The Court emphasized that its interpretation aligns with the NMUPA’s goals of ensuring that all parents contribute equitably to their children’s financial support and protecting the interests of children in their own support. The Court also considered and rejected the father’s equitable arguments against retroactive support, noting that the district court had appropriately considered whether equitable defenses were applicable (paras 14-33).