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

• A vehicle collision on New Mexico Highway 599 resulted in one death and severe injuries to the Plaintiffs. The collision occurred when another driver failed to yield at an intersection, colliding with the Plaintiffs' vehicle. The Plaintiffs sued the New Mexico Department of Transportation (DOT), alleging that inadequate traffic controls and warnings at the intersection caused the collision. During discovery, DOT produced a Final Project Prioritization Plan for the NM 599 Corridor, which had been prepared to aid in prioritizing construction improvements along NM 599 and recommended constructing an interchange at the accident's intersection (paras 2-3).

Procedural History

• District Court of Santa Fe County: Excluded the Final Project Prioritization Plan from evidence under a federal statutory evidentiary privilege and denied DOT's bill of costs following a jury verdict in favor of DOT (para 1).

Parties' Submissions

• Plaintiffs: Argued that DOT waived its right to assert the federal statutory evidentiary privilege by producing the Plan during discovery and contended that the district court applied too broad an interpretation of the privilege (para 1).
• Defendant (DOT): Contended that the Plan was publicly available, so no harm was done in producing it during discovery, and argued that the district court erred by failing to include the required “good cause” for denying their bill of costs (paras 7, 20).

Legal Issues

• Whether the district court erred in excluding the Final Project Prioritization Plan under a federal statutory evidentiary privilege (para 6).
• Whether the district court erred in denying DOT's bill of costs without providing "good cause" (para 20).

Disposition

• Affirmed the district court’s exclusion of the Plan.
• Reversed the district court’s denial of the bill of costs.
• Remanded with instructions for the district court to file an amended order specifying the reasons for its decision to deny costs (para 23).

Reasons

• The Court found that the district court did not err in excluding the Plan under the federal statutory evidentiary privilege, as the privilege was not waived by producing the Plan during discovery or by failing to produce a privilege log. The Court adopted a narrow interpretation of the privilege, consistent with federal case law, determining that the Plan was prepared with the intention to be used in a particular highway safety construction improvement project and thus was protected under the privilege. Regarding the bill of costs, the Court agreed with DOT that the district court erred by not providing "good cause" for its denial, as required by law, and remanded for further proceedings to specify the reasons for the denial (paras 6-22).