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 trustees of the Yogi Bhajan Administrative Trust sued Yogi Bhajan's widow, seeking a declaratory judgment that she is not entitled to any distributions from the trust. The litigation, which has lasted over thirteen years, involved the parties' competing claims to funds awarded in an arbitration with a third party. The district court determined that the plaintiffs' writ of garnishment had priority over the defendant's counsel's claimed charging lien on the arbitration award. The defendant appealed this decision.

Procedural History

• Khalsa v. Puri, 2015-NMCA-027, 344 P.3d 1036: The Court of Appeals affirmed the district court's order requiring the defendant to pay attorney fees and costs to the plaintiffs.
• [Not applicable or not found]: The decision to analyze is the defendant's fourth appeal in this litigation.

Parties' Submissions

• Plaintiffs-Appellees: Argued that their writ of garnishment on the defendant's share of funds from an arbitration award should have priority over the defendant's counsel's charging lien.
• Defendant-Appellant: Contended that the district court lacked authority to determine the priority between the garnishment and the charging lien and that the garnishment should not have priority.

Legal Issues

• Whether the district court had authority to determine priority between the plaintiffs' writ of garnishment and the defendant's counsel's charging lien.
• Whether the district court erred in concluding that the garnishment had priority over the charging lien.

Disposition

• The Court of Appeals affirmed the district court's judgment that the plaintiffs' writ of garnishment had priority over the defendant's counsel's claimed charging lien.

Reasons

• Per Ives, J. (Zamora and Henderson, JJ., concurring):
  The district court had the authority to determine the priority between the plaintiffs' writ of garnishment and the defendant's counsel's charging lien. The court's jurisdiction and the applicability and construction of a contract requiring arbitration were reviewed de novo, and the court found no clear and unmistakable evidence that the parties intended to delegate questions of arbitrability to the arbitrator (paras 5-8).
  The district court did not err in deciding that the dispute was not subject to arbitration. The parties did not agree to arbitrate the priority dispute, and the arbitration provision within the Exclusive Licensing Agreement did not apply to the present dispute (paras 9-10).
  The district court did not abuse its discretion in determining that the plaintiffs' garnishment had priority over the defendant's counsel's charging lien. The court considered the longstanding indebtedness of the defendant to the plaintiffs and the lack of evidence of the defendant's financial status or indebtedness to her attorney (paras 14-18).