AI Generated Opinion Summaries

Decision Information

Decision Content

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

  • Sabrina Owens, an assistant manager employed by Bernard/Allison Management Services, Inc., was injured while walking down steps in the parking lot of the Las Kivas Apartment Complex, managed by Bernard/Allison for the Complex's owners (Appellees). Owens received workers' compensation benefits from Bernard/Allison and sought to recover tort damages from the Appellees for her injuries (paras 1-2).

Procedural History

  • District Court of Santa Fe County, Barbara J. Vigil, District Judge: Granted summary judgment in favor of Appellees, concluding that Owens' remedies were limited to those provided under the Workers’ Compensation Act as Appellees were deemed Owens’ statutory employers (para 1).

Parties' Submissions

  • Plaintiff-Appellant (Owens): Sought to recover tort damages from the Appellees for injuries sustained, arguing that the Appellees were not her statutory employers under the Workers’ Compensation Act (paras 1-2).
  • Defendants-Appellees: Argued that they were Owens’ statutory employers and, as such, her remedies were limited to those provided under the Workers’ Compensation Act. They relied on the affidavit of Mark Hamilton and the Property Management Agreement to support their motion for summary judgment (paras 2, 6).

Legal Issues

  • Whether the Appellees were Owens’ statutory employers under the Workers’ Compensation Act, thereby limiting her remedies to those provided under the Act (para 2).
  • Whether Bernard/Allison was an independent contractor and whether its work was a part or process in the trade or business or undertaking of the Appellees (paras 4, 14).

Disposition

  • The Court of Appeals reversed the district court’s grant of summary judgment in favor of Appellees and remanded the case (para 15).

Reasons

  • The Court, with an opinion by Judge Michael D. Bustamante, and concurrence by Judges Jonathan B. Sutin and Linda M. Vanzi, held that the Appellees failed to make a prima facie case entitling them to summary judgment. The Court found that the affidavit and the Property Management Agreement did not conclusively establish that Appellees had control over the day-to-day operations of Bernard/Allison to the extent required to deem them statutory employers under the Workers’ Compensation Act. The Court also noted that Owens provided sufficient evidence to create genuine issues of fact regarding whether Bernard/Allison was an independent contractor and whether its work was a part or process of the Appellees' business, precluding summary judgment. The Court emphasized the need for caution in applying summary judgment and the importance of viewing evidence in the light most favorable to a trial on the merits (paras 3-14).
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