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Facts

  • On November 26, 2006, Jeremy Singleton was driving a vehicle in Douglas County, Colorado, with multiple passengers when he struck a deer, causing the vehicle to roll over. Jeremy Singleton and Jennessa Singleton were killed, Nora Arbelaez died from her injuries, and Vennessa Arbelaez, Omar Arbelaez, and Jeremiah Singleton sustained serious injuries. Plaintiffs filed a complaint seeking damages for wrongful death and personal injuries against Jeremy Singleton and American National Property and Casualty Company (ANPAC), leading to a settlement agreement (paras 2-3).

Procedural History

  • District Court of Sandoval County, November 25, 2008: Approved a settlement agreement between Plaintiffs and ANPAC, dismissing the case with prejudice.
  • Federal District Court, March 19, 2012: Granted summary judgment in favor of ANPAC, concluding that the settlement agreement could not be reopened based on retroactive application of Supreme Court decisions.

Parties' Submissions

  • Plaintiffs: Argued for relief from judgment based on two Supreme Court decisions that would affect the insurance coverage amounts, claiming the settlement was inequitable in light of these decisions (para 6).
  • ANPAC: Filed a declaratory judgment action seeking a declaration that Plaintiffs were bound by the terms of the settlement agreement and opposed Plaintiffs' motion for relief from judgment, arguing that the settlement agreement was final and could not be reopened (paras 5, 7).

Legal Issues

  • Whether the district court erred in denying Plaintiffs' motion for relief from judgment based on the collateral estoppel effect of a federal court's granting of summary judgment against Plaintiffs.
  • Whether the federal district court had subject matter jurisdiction over the declaratory judgment action filed by ANPAC.

Disposition

  • The Court of Appeals affirmed the district court's denial of Plaintiffs' motion for relief from judgment (para 12).

Reasons

  • The Court of Appeals, per Judge Linda M. Vanzi, with Judges Michael E. Vigil and M. Monica Zamora concurring, held that the district court did not err in denying the motion for relief from judgment. The court applied the doctrine of collateral estoppel, determining that the issues had been finally adjudicated on the merits in the federal court action, and Plaintiffs had a full and fair opportunity to litigate those issues. The court also declined to allow Plaintiffs to challenge the subject matter jurisdiction of the federal district court in this proceeding, citing precedent that a party may not collaterally attack a final judgment on subject matter jurisdiction grounds when the party had the opportunity to challenge it during the original action. The court found no exceptions to this rule applied and rejected Plaintiffs' contention that the district court disregarded its role as a separate sovereign (paras 7-11).
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