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

• Ken Snow, an operator at Navajo Refinery, was seriously injured during a "turn-around" process on January 20, 2009, when a hose assembly came loose and struck him. Snow and his wife filed a complaint for personal injury, loss of consortium, and punitive damages on August 15, 2011, initially naming Midwest Hose & Specialty, Inc., Gandy Corporation, Repcon, Inc., and Holly Corporation as defendants. Through discovery, they learned that Warren Power & Machinery, Inc. d/b/a Warren CAT (Warren) and Brininstool Equipment Sales (Brininstool) provided equipment used during the turn-around and sought to amend their complaint to add these entities as defendants (paras 2-3).

Procedural History

• District Court, January 27, 2012: Granted the Snows' motion for leave to file a second amended complaint adding Warren and Brininstool as defendants after the statute of limitations had expired (para 6).
• Court of Appeals, 2014-NMCA-054: Affirmed the district court's decision, holding that neither the doctrine of equitable tolling nor the relation back under Rule 1-015(C) saved the late filing of the second amended complaint against Warren and Brininstool (para 9).

Parties' Submissions

• Plaintiffs-Petitioners: Argued that the delay inherent in the rule requiring leave of court to file an amended complaint unfairly truncated the statute of limitations period, and that the second amended complaint should be "deemed" filed at the time the motion requesting leave was filed because it was attached to the motion. Alternatively, argued that the second amended complaint should relate back to the original filing date under Rule 1-015(C) NMRA (para 8).
• Defendants-Respondents: Asserted as an affirmative defense that the claims against them were barred by the three-year statute of limitations and filed motions for summary judgment based on this defense (para 8).

Legal Issues

• Whether the Snows' Motion for Leave to file Plaintiffs’ Second Amended Complaint tolled the statute of limitations when they attached the proposed Second Amended Complaint to the Motion (para 11).

Disposition

• The Supreme Court of the State of New Mexico reversed the Court of Appeals' decision, holding that the second amended complaint is deemed filed as of the date of the original motion for leave to file, thus the statute of limitations is not a bar (para 1).

Reasons

• Per Bosson, J., with Vigil, C.J., Maes, Chávez, and Daniels, JJ., concurring:
  The Court recognized the issue of whether a motion for leave to amend a complaint, filed before the statute of limitations expires but granted after, tolls the statute of limitations. It concluded that such a motion does toll the statute, deeming the amended complaint filed as of the date of the motion (paras 1, 24-33).
  The Court noted the public interest in resolving this significant concern with pleading rules and the potential for systemic delays inherent in the electronic filing system and court processing times to unfairly truncate the statute of limitations period (paras 11-16, 22-23).
  The Court rejected the application of Rule 1-015(C) for relation back in this context, finding it did not address the specific situation of court delay in granting leave to amend (para 21).
  The Court adopted a "deeming" rule, similar to that used in Massachusetts and Florida, allowing the filing date of the motion for leave to amend, with the amended complaint attached, to stand in place of the filing date for the amended complaint for statute of limitations purposes (paras 30-33).
  The Court declined to impose a requirement for plaintiffs to notify potential new defendants of the intent to sue before the statute of limitations runs or to amend Rule 1-004 to provide a more definite time period for service of process, leaving these matters for future consideration by the appropriate rules committee (paras 36-37).