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 Tafoyas sought an easement along a driveway established by Cecilia Tafoya's father when he split his property, transferring one lot to Cecilia and retaining the rear lot, which was later owned by the Morrisons. The Tafoyas claimed various forms of easement over the Morrisons' land for access to their property. The case involved a history of family disputes over the easement and property rights, leading to multiple legal proceedings.

Procedural History

• Redman-Tafoya v. Armijo, 2006-NMCA-011: Contained the history of family battles over the easement up to January 2004.
• District Court's grant of summary judgment against the Tafoyas: Stemmed from the conclusion that the Tafoyas' easement claims were barred due to previous litigation in an inheritance revocation case and that their claim to a prescriptive easement was without merit.
• Comprehensive settlement agreement and mutual release: Entered into by Cecilia Tafoya, her brother (acting as personal representative of their father's estate), and one of their sisters in January 2006, following the reversal of the district court's revocation of Cecilia's inheritance.

Parties' Submissions

• Tafoyas: Argued that res judicata and collateral estoppel do not bar their claims for a driveway easement over the Morrisons' land, that they did not have a full and fair opportunity to litigate their easement claim in the revocation proceeding, and that there is no legal basis to bar their prescriptive easement and easement by necessity claims against the Morrisons.
• Morrisons: Moved for summary judgment based on the doctrines of res judicata, collateral estoppel, and settlement and release, asserting that the Tafoyas' easement claims were barred due to previous litigation and the comprehensive settlement agreement.

Legal Issues

• Whether the doctrine of res judicata bars the Tafoyas from claiming a driveway easement over the Morrisons' land.
• Whether the Tafoyas had a full and fair opportunity to litigate their claim to an easement in the revocation proceeding.
• Whether the Tafoyas' prescriptive easement and easement by necessity claims against the Morrisons are barred by res judicata, collateral estoppel, or the settlement agreement.

Disposition

• The court affirmed the district court's grant of summary judgment against the Tafoyas as to the express, implied, and by-necessity easement claims on the basis of res judicata.
• The court also affirmed the district court's grant of summary judgment against the Tafoyas on their prescriptive easement claim.

Reasons

• The court held that the Tafoyas' claims for an express easement, implied easement, and easement by necessity were properly precluded under the doctrine of res judicata because the parties were in privity, the cause of action was the same as in the revocation proceeding, and there was a final decision on the merits in the first suit (paras 33-47).
  The court also found that the Tafoyas had a full and fair opportunity to litigate their easement claims during the revocation proceeding, thus satisfying the essence of res judicata (paras 56-57).
  Regarding the prescriptive easement claim, the court agreed with the district court that the Tafoyas failed to establish adverse use of the land for the required 10-year period, as their use was permissive up to at least 2004, and the Morrisons installed a fence in 2013, cutting off any potential adverse use before the 10-year period could be completed (paras 60-67).