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 Plaintiff, dissatisfied with the Defendants' handling of his personal injury case, particularly their alleged failure to pursue discovery as early as 2015, filed a malpractice action. He argued that his case was not viable until he obtained a training manual that established the standard of care in a personal injury lawsuit, which he used to prevail in his personal injury suit (paras 5-6).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellant: Argued that the malpractice action was timely because his cause of action did not accrue until he obtained a training manual that established the standard of care necessary to prevail in his personal injury lawsuit. He also sought to introduce new evidence to establish “reasonable doubt” about facts relied upon by the district court in granting summary judgment (paras 2, 5-6).
• Defendants-Appellees: Filed a memorandum in opposition to the proposed disposition by the Court of Appeals, which had suggested affirming the summary judgments against the Plaintiff. The Defendants maintained that the malpractice action was barred by the statute of limitations and that there were no disputed facts preventing the grant of summary judgment (para 1).

Legal Issues

• Whether the Plaintiff's malpractice action was barred by the statute of limitations prescribed by NMSA 1978, Section 37-1-4 (1880).
• Whether the Plaintiff could introduce new evidence on appeal to establish “reasonable doubt” about facts relied upon by the district court in granting summary judgment (paras 2-3).

Disposition

• The Court of Appeals affirmed the summary judgments entered by the district court, concluding that the Plaintiff's malpractice action was barred by the statute of limitations and that the Plaintiff could not introduce new evidence on appeal to contest the facts established below (para 9).

Reasons

• MEDINA, Judge (with IVES, Judge and YOHALEM, Judge concurring): The Court held that the Plaintiff's malpractice action was untimely as it was filed beyond the four-year statute of limitations period. The Court rejected the Plaintiff's argument that his cause of action did not accrue until he obtained a training manual, clarifying that a legal cause of action accrues when the plaintiff knows or should know the relevant facts, regardless of whether the plaintiff also knows that these facts are enough to establish a legal cause of action. The Court also determined that the Plaintiff could not introduce new evidence on appeal that was not part of the record below, adhering to the principle that appellate courts do not consider matters outside the record. The Court found that the Plaintiff's arguments did not meet the burden of pointing out errors in fact or law in the proposed summary disposition and thus affirmed the summary judgments (paras 1-8).