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 January 20, 2009, Plaintiff Ken Snow was injured at Navajo Refinery when a hose assembly detached from a water pump and struck him. The hose was manufactured by Midwest Hose & Specialty, Inc., sold to Warren CAT, rented to Brininstool Equipment Sales, and then supplied to Navajo Refinery. Ken Snow and his wife, Allene Snow, sought damages for his injuries (para 2).

Procedural History

• District Court of Santa Fe County, Sheri A. Raphaelson, District Judge: Summary judgment granted to Defendants Warren Power & Machinery, Inc., d/b/a Warren CAT, and Brininstool Equipment Sales based on the statute of limitations (para 1).

Parties' Submissions

• Plaintiffs: Argued that the statute of limitations should not bar their claims against Warren CAT and Brininstool due to the applicability of the relation-back theory under Rule 1-015(C) NMRA and the doctrine of equitable tolling (para 6).
• Defendants (Warren CAT and Brininstool): Asserted that the statute of limitations had expired prior to the filing of the second amended complaint, thus barring Plaintiffs’ claims (para 4).

Legal Issues

• Whether the statute of limitations expired despite Plaintiffs’ motion to amend filed on the last day of the applicable limitation period (para 1).
• Whether the relation-back theory under Rule 1-015(C) NMRA applies in this case (para 7).
• Whether the doctrine of equitable tolling applies to toll the statute of limitations (para 17).

Disposition

• The Court of Appeals affirmed the district court’s grant of summary judgment in favor of Warren CAT and Brininstool, holding that the statute of limitations expired prior to the filing of Plaintiffs’ second amended complaint and neither the relation-back theory nor the doctrine of equitable tolling applied (para 25).

Reasons

• The Court, per Judge Timothy L. Garcia with Chief Judge Roderick T. Kennedy and Judge J. Miles Hanisee concurring, held that the district court did not err in granting summary judgment based on the expiration of the statute of limitations. The Court found that Plaintiffs failed to satisfy the requirements of Rule 1-015(C) for the relation-back theory as there was no mistake concerning the identity of the proper party and Plaintiffs did not demonstrate due diligence in identifying Warren CAT and Brininstool as defendants before the statute of limitations expired (paras 8-16). Furthermore, the Court rejected the application of the doctrine of equitable tolling, noting that Plaintiffs did not demonstrate they were prevented from filing suit due to extraordinary circumstances beyond their control and failed to establish diligent pursuit of their rights (paras 17-24).