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

• In the 1980s, Plaintiff Maura Schmierer and her then-husband joined Free Love Ministries, controlled by Defendants Jim and Lila Green. Schmierer was later accused of "spiritual adultery," excommunicated, and confined to a shed by the Greens. After escaping, Schmierer sued in California, obtaining a default judgment against the Greens and others in 1989. The Defendants obstructed judgment satisfaction by damaging property and hiding assets. Schmierer tracked them to New Mexico, where they had acquired property under trust names. In 2004, she filed suit in New Mexico to domesticate and enforce the California judgment (paras 2-5).

Procedural History

• California Superior Court, March 10, 1989: Default judgment awarded to Schmierer against Defendants for $1,020,046 (para 3).
• [Not applicable or not found]: Schmierer renewed the California judgment on March 9, 1999, extending its enforceability (para 7).
• District Court of Cibola County, December 3, 2015: Dismissed Schmierer’s petition, ruling the California judgment time-barred under New Mexico law (para 12).

Parties' Submissions

• Plaintiff: Argued the California judgment was not time-barred, having been renewed in 1999, and sought to enforce it against Defendants' assets in New Mexico, alleging fraudulent transfer to evade the judgment (paras 8-9).
• Defendants: Contended the California judgment was stale under New Mexico law and enforcement was barred by the state's fourteen-year statute of limitations (para 9).

Legal Issues

• Whether the California judgment, renewed in 1999, was time-barred under New Mexico’s fourteen-year statute of limitations for enforcing judgments (para 1).
• Whether full faith and credit was given to the California judgment as required under the United States Constitution (para 15).

Disposition

• The Court of Appeals of the State of New Mexico reversed the district court's dismissal, holding the California judgment was not time-barred and remanded for further proceedings (para 36).

Reasons

• The Court of Appeals, per Bohnhoff, J., with Vanzi, C.J., and Zamora, J., concurring, found that the district court erred in dismissing Schmierer's petition on statute of limitations grounds. The court reasoned that under the Full Faith and Credit Clause of the U.S. Constitution, the California judgment, having been renewed in 1999, effectively reset the enforcement clock, allowing Schmierer until 2009 to bring an action in New Mexico. The court distinguished between procedural statutes of limitations and substantive policies regarding judgment revival, concluding that New Mexico must respect California's policy allowing judgment renewal. Thus, the effective date of the judgment for purposes of New Mexico's statute of limitations was 1999, not 1989, making Schmierer's 2004 action timely (paras 13-35).