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 case involves a jury finding that Defendants Andrew Davis and Carly Montgomery defamed and intentionally inflicted emotional distress on Plaintiff Kaitlin Warner, awarding her $64,000 in damages, including punitive damages. The defamation and distress were primarily related to statements posted on Facebook and a business page co-owned by the Defendants, which falsely accused Warner of being a juvenile felon and committing perjury. Warner experienced significant emotional distress and moved out of New Mexico as a result of these posts.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendants: Argued that the verdict and award of punitive damages were not supported by substantial evidence. They contended that there was no evidence of publication by Davis, no evidence of actual damages such as lost opportunities or medical costs presented by Warner, and that Montgomery did not cause any damages. They also argued that their conduct did not amount to extreme and outrageous behavior necessary for a claim of intentional infliction of emotional distress and that the punitive damages were unjustified as they did not act with actual malice.
• Plaintiff (Warner): Maintained that the jury's verdict and the award for punitive damages were supported by substantial evidence. Warner argued that the defamation and emotional distress she suffered due to the Defendants' actions were significant, pointing to the impact of the false statements on her life and well-being.

Legal Issues

• Whether the jury’s verdict and award of punitive damages were supported by substantial evidence.
• Whether the district court erred by allowing Warner to file an untimely notice of appeal.
• Whether the district court erred by not admitting Defendants’ request for admission addressing sexual intercourse as an exhibit at trial.

Disposition

• The jury’s verdict against Defendants and the award for punitive damages are affirmed.
• The district court did not abuse its discretion by allowing Warner to file an untimely notice of appeal and by not admitting Defendants’ request for admission as an exhibit at trial.

Reasons

• MEDINA, Judge; BOGARDUS, Judge; DUFFY, Judge (concurring):
  The Court held that the jury’s verdict on defamation and intentional infliction of emotional distress was supported by substantial evidence. Evidence showed that Montgomery posted defamatory statements on a Facebook business page co-owned with Davis, who did not remove the posts despite knowing their falsity, supporting publication by Davis (paras 4-6, 8-9). Warner's testimony on the impact of these posts provided sufficient evidence of her emotional distress and harm to her reputation, justifying the damages awarded (paras 5-6, 9).
  Regarding punitive damages, the Court found that Defendants acted with actual malice, as Montgomery posted false statements without verifying their truth and Davis did nothing to remove the posts despite knowing their falsity (paras 10-12).
  The Court also found no abuse of discretion in the district court’s decision to grant Warner an extension to file a notice of cross-appeal, citing Defendants’ procedural errors that led to confusion (paras 14-17).
  On Warner’s cross-appeal about the exclusion of evidence, the Court held that the district court did not abuse its discretion. Warner was allowed to present testimony and read the request for admission into the record, mitigating any potential prejudice from not admitting it as an exhibit (paras 18-21).