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 case involves the family members and the personal representative of the estate of a New Mexico resident, Jose Barron (Decedent), who underwent a biopsy procedure at Memorial Medical Center (MMC) in Las Cruces, New Mexico. After the procedure, Decedent suffered a carotid artery bleed and was transferred to Las Palmas Medical Center in El Paso, Texas, for further treatment under a transfer agreement between MMC and Las Palmas. The Plaintiffs alleged that MMC failed to communicate the specific location requiring repair to Las Palmas and that Las Palmas did not perform the necessary repair on Decedent's carotid artery, leading to his death in New Mexico after seeking further help at MMC (para 2).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiffs-Appellants: Argued that the Defendant, a nonresident hospital, is subject to personal jurisdiction in New Mexico due to the medical malpractice that occurred in Texas, which they claim was a cause of Decedent’s death in New Mexico. They also requested remand for jurisdictional discovery against Defendant but did not specify what discovery would lead to facts supporting personal jurisdiction (paras 3, 7-9).
• Defendants-Appellees: Contended that they are not subject to personal jurisdiction in New Mexico, emphasizing that their registration under New Mexico’s Uniform Revised Limited Partnership Act and their operation of a bariatric referral clinic in Albuquerque do not establish continuous contacts or show that they availed themselves of conducting activities within New Mexico for the purposes of general or specific personal jurisdiction (paras 4, 8).

Legal Issues

• Whether the nonresident Defendant hospital is subject to personal jurisdiction in New Mexico arising from allegations of medical malpractice in Texas that led to Decedent’s death in New Mexico (para 3).
• Whether Plaintiffs established a prima facie case to support the exercise of specific personal jurisdiction over Defendant (para 5).
• Whether Plaintiffs abandoned their argument for general personal jurisdiction based on Defendant’s registration to do business in New Mexico (para 11).

Disposition

• The dismissal of Defendant for lack of personal jurisdiction is affirmed (para 13).

Reasons

• The Court, consisting of Judges Wray, Hanisee, and Duffy, affirmed the district court's dismissal for lack of personal jurisdiction. The Court found that Plaintiffs did not make a prima facie showing of specific personal jurisdiction over Defendant, as their activities in New Mexico were limited to bariatric referrals and did not broadly cultivate a market for medical services related to the cause of action. The Court also noted that Plaintiffs' cause of action was not related to Defendant’s purposeful contacts in New Mexico. Furthermore, the Court addressed that Plaintiffs abandoned their argument for general personal jurisdiction following the Supreme Court’s decision in Chavez II, which overruled precedent that might have supported their consent-by-registration argument. The Court concluded that the relationship among Defendant, the forum, and the litigation was not close enough to support specific personal jurisdiction and declined to review the general personal jurisdiction argument due to its abandonment by Plaintiffs (paras 5-12).