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, Rosanne Aragon, both individually and as the parent and next friend of Joe Anthony Alderete (a minor child), filed a lawsuit against Defendants Allstate Insurance Company (Allstate) and Frankie Cabrera (Cabrera). The lawsuit involved claims for punitive damages and insurance bad faith following an incident where Cabrera, allegedly driving under the influence, rear-ended a car. The Plaintiff sought to introduce evidence of Cabrera's criminal history and another unrelated criminal case to support their claims (para 4).

Procedural History

• Appeal from the District Court of Santa Fe County, Francis J. Mathew, District Judge, March 20, 2018: Jury verdicts favored Defendants Allstate and Cabrera on Plaintiff’s punitive damages and insurance bad faith claims.

Parties' Submissions

• Plaintiff: Argued that the district court erred by excluding evidence of Cabrera’s criminal history and an unrelated criminal case, which was relevant to their claims. Also contended that the district court improperly commented on the evidence and erred in denying their motion for contempt based on an affidavit asserted to be made in bad faith. Additionally, the Plaintiff argued against the dismissal of the Child’s insurance bad faith claim on the grounds that a minor cannot legally enter into a contract (paras 4-8).
• Defendant Allstate: Supported the district court's decisions to exclude evidence of Cabrera’s criminal history, deny the Plaintiff's motion for contempt, and dismiss the Child’s insurance bad faith claim. Allstate also argued that the district court did not improperly comment on the evidence (paras 4-8).
• Defendant Cabrera: [Not applicable or not found]

Legal Issues

• Whether the district court erred in excluding evidence of Cabrera’s criminal history and an unrelated criminal case.
• Whether the district court improperly commented on the evidence.
• Whether the district court erred in denying Plaintiff’s motion for contempt based on an affidavit alleged to be made in bad faith.
• Whether the district court erred in dismissing the Child’s insurance bad faith claim on the ground that a minor cannot legally enter into a contract.

Disposition

• The Court of Appeals affirmed the district court's decisions on all contested issues (para 9).

Reasons

• M. Monica Zamora, Judge (J. Miles Hanisee, Judge, and Daniel J. Gallegos, Judge, concurring): The Court found that the evidence Plaintiff sought to introduce regarding Cabrera’s criminal history was irrelevant and inadmissible under Rule 11-404(B)(1) NMRA. It also concluded that the district court did not improperly comment on the evidence, as the statement challenged by the Plaintiff was made by Allstate, not the district court. Regarding the motion for contempt, the Court held that the Plaintiff had not demonstrated that the district court's determination was unsupported by evidence or based on a misunderstanding of the law. Finally, the Court found no error in the district court's dismissal of the Child’s insurance bad faith claim, as the Plaintiff failed to provide any citation to facts or authority demonstrating how the district court’s ruling was erroneous (paras 4-8).