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

• On December 29 and 30, 2011, Andy Denny, after a night of drinking, ran out of gasoline near Tohatchi, New Mexico. Denny and his passenger, both intoxicated, walked to the Defendant's gas station to purchase gasoline. Initially refused service due to their intoxication, they were eventually sold a gallon of water (which they emptied to use as a container) and a gallon of gasoline. They returned to Denny's vehicle, refueled, and then purchased an additional nine gallons of gasoline. After dropping off his passenger, Denny collided with Marcellino Morris's vehicle, resulting in Morris's death. Denny was found to be intoxicated at the scene (paras 4-7).

Procedural History

• District Court of the Navajo Nation: Found Plaintiff’s complaint was barred due to the lapse of the Navajo Nation’s two-year statute of limitations for personal injury (para 3).
• Navajo Nation Supreme Court, No. SC-CV-13-15: Affirmed the District Court of the Navajo Nation's summary judgment order (para 105).

Parties' Submissions

• Plaintiff: Argued that Defendant, Giant Four Corners, negligently entrusted gasoline to an intoxicated driver, which led to the death of Plaintiff’s son in an auto accident (para 3).
• Defendant: Contended that New Mexico law does not create a duty to refrain from selling gasoline to an intoxicated driver and moved for judgment on the pleadings, asserting the absence of a specific duty in this context (para 8).

Legal Issues

• Whether a commercial gasoline vendor owes a duty of care to a third party using the roadway to refrain from selling gasoline to a driver it knows or should know to be intoxicated (para 1).

Disposition

• The Supreme Court of the State of New Mexico answered in the affirmative to the certified question, establishing that under New Mexico law and the doctrine of negligent entrustment of chattel, a commercial gasoline vendor does owe a duty of care to refrain from selling gasoline to a driver known or should be known to be intoxicated (para 47).

Reasons

• The Court, led by Justice Bacon, based its decision on the principles of negligent entrustment of chattel, recognizing that New Mexico law has long acknowledged negligent entrustment as a viable cause of action. The Court examined whether the duty inherent in negligent entrustment extends to vendors of gasoline who sell to intoxicated drivers. It concluded that public policy considerations, including the Legislature's intent to limit intoxicated driving and the recognition of liability for providing vehicles to intoxicated individuals, support a duty to refrain from supplying gasoline to intoxicated drivers. The Court found persuasive the analogy between providing a vehicle and providing gasoline to an intoxicated person, as both enable driving while intoxicated. The decision was grounded in the analysis of New Mexico statutes, case law, and general principles of law, emphasizing the need for compensation for the injured and deterrence of tortfeasors. Justice Barbara J. Vigil, retired, dissenting, expressed concern over extending negligent entrustment to commercial transactions and the potential for unreasonable and uncertain duties on vendors (paras 9-48, 49-105).