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 case involves the Plaintiffs suing the Defendant for breaches of a residential lease agreement, where the Defendant entered the agreement as "trustee and/or general manager" of "Bear International Trust." The Plaintiffs obtained a judgment against the Defendant for $6,873.22 plus prejudgment interest. Subsequently, the Plaintiffs sought discovery to enforce the judgment, requesting financial information about Bear International and any other accounts associated with the Defendant. The Defendant objected to these requests, leading to a motion to compel discovery and, eventually, a contempt order against the Defendant for failing to comply with the discovery order (paras 2-7).
Procedural History
- District Court of Bernalillo County: Plaintiffs obtained a judgment against Defendant for $6,873.22 plus prejudgment interest (para 2).
- District Court of Bernalillo County: Issued an order compelling discovery against Defendant, who failed to adequately respond to Plaintiffs' discovery requests (para 4).
- District Court of Bernalillo County: Held Defendant in contempt for violating the order compelling discovery (para 7).
Parties' Submissions
- Plaintiffs: Argued that the information relating to Bear International was relevant for the enforcement of the judgment since the Defendant had previously testified he was an owner of several properties through Bear International. They contended that the Defendant's objections were invalid as the discovery rules apply to compel any person with knowledge that will aid in enforcement of the judgment (paras 3-4).
- Defendant: Objected to answering interrogatories and requests for production seeking information about Bear International on the basis that the trust was not a party to the matter and the information sought was not relevant. Also argued that the information was confidential and that Plaintiffs should obtain it directly from the third-party under specific rules (paras 4, 9-10).
Legal Issues
- Whether the district court erred in holding the Defendant in contempt for failing to comply with an order compelling discovery (para 1).
- Whether the information sought by Plaintiffs regarding Bear International was relevant and discoverable (paras 9-11).
- Whether the Defendant's objections to discovery on the basis of confidentiality and third-party status were meritorious (paras 9-14).
Disposition
- The New Mexico Court of Appeals affirmed the district court's order holding the Defendant in contempt for violating the order compelling discovery (para 16).
Reasons
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Per HANISEE, Chief Judge (ATTREP, J., and HENDERSON, J., concurring): The Court found no abuse of discretion in the district court's decisions. It rejected the Defendant's arguments that his objections to discovery were meritorious and made in good faith, noting that the Defendant failed to respond to the motion to compel discovery and did not argue confidentiality or the necessity to proceed under specific rules for third-party discovery at the lower court level. The Court also found the information sought by Plaintiffs to be relevant for enforcing the judgment against the Defendant, as it could reveal assets owned by the Defendant, whether as part of a trust or not, that were available to satisfy the judgment. The Court concluded that the district court did not abuse its discretion in compelling discovery or in holding the Defendant in contempt for failing to comply with the discovery order (paras 8-15).
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