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

• Daniel Salas (Decedent) worked in various jobs in California and New Mexico, including home construction and as a miner and mechanic, where he was exposed to products containing respirable asbestos. Diagnosed with lung cancer associated with asbestos in 2013, he passed away later that year. Litigation began in California in 2013, and in New Mexico in 2014, his estate and family members filed suit against numerous defendants, alleging wrongful death due to asbestos exposure. Most claims were settled, leaving only the Defendants in this appeal (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiffs-Appellants: Argued that Defendants had not made a prima facie showing for summary judgment, thus not shifting the burden to present material facts. They also contended that the factual record was insufficiently developed for the district court to rule on summary judgment and included additional evidence in their motion to reconsider (paras 9-10, 13-14, 29).
• Defendants-Appellees: Each filed motions for summary judgment, arguing that Plaintiffs failed to demonstrate specific causation or link Decedent’s asbestos exposure to their respective products. They supported their motions with Plaintiffs’ untimely designation of expert witnesses, expert reports from unrelated litigation, and Plaintiffs’ unverified interrogatory responses (paras 9-12).

Legal Issues

• Whether Defendants made prima facie showings that no material facts existed, shifting the burden to Plaintiffs to demonstrate the existence of material facts.
• If so, whether Plaintiffs carried their burden in responding to Defendants’ motions for summary judgment.
• Whether the district court erred in granting summary judgment for Defendants and in denying Plaintiffs' motion to reconsider (paras 6, 29).

Disposition

• The grant of summary judgment and denial of the motion to reconsider as to Goodrich Corporation, Clark Equipment Company, and Federal-Mogul Personal Injury Trust were affirmed.
• The grant of summary judgment for Foxworth Galbraith Lumber Company (FGLC) was reversed, and the case was remanded to the district court for further findings of fact and conclusions of law regarding causation evidence as to FGLC (para 34).

Reasons

• The Court held that Goodrich, Clark, and Federal-Mogul each made prima facie showings of entitlement to summary judgment, and Plaintiffs did not carry their burden as prescribed by Rule 1-056 NMRA, thus summary judgment was appropriately granted for these Defendants. However, the Court found that the district court erroneously determined that affidavits submitted by Plaintiffs in response to FGLC's motion for summary judgment were sham affidavits and improperly disregarded them. The Court instructed the district court to enter clear findings of fact and conclusions of law regarding whether Plaintiffs produced evidence that FGLC products were a general and specific cause of Decedent’s harm. The Court also concluded that the district court did not abuse its discretion in denying Plaintiffs' motion to reconsider as to Goodrich, Clark, and Federal-Mogul, noting that Plaintiffs failed to demonstrate specific evidentiary facts in response to Defendants' motions for summary judgment and did not properly seek additional time to develop the factual record (paras 6-34).