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

• A worker filed for attorney fees against their employer, Intel Corporation, under a statutory fee-shifting provision after a workers' compensation claim. The dispute centered on the interpretation of the worker's offer of judgment in relation to the final compensation awarded, specifically regarding the application of credits and/or offsets as per the relevant statutes.

Procedural History

• APPEAL FROM THE WORKERS’ COMPENSATION ADMINISTRATION, David L. Skinner, Workers’ Compensation Judge: The Workers' Compensation Judge awarded attorney fees to the worker.

Parties' Submissions

• Worker-Appellee: Argued that the offer of judgment was clear and unambiguous, allowing for the application of credits and offsets as per NMSA 1978, Section 52-1-25.1, and thus entitled the worker to attorney fees under the fee-shifting provision (paras 4-5).
• Employer-Appellant: Contended that the worker's offer of judgment should be considered higher than the amount ultimately recovered due to the absence of express language for credits/offsets, making it inappropriate for fee-shifting. Alternatively, argued that the offer was ambiguous and did not provide a clear basis for fee-shifting (paras 4-6).

Legal Issues

• Whether the worker's offer of judgment was clear and unambiguous regarding the application of credits and offsets, thus providing a basis for the application of the statutory fee-shifting provision.

Disposition

• The Court of Appeals affirmed the Workers' Compensation Judge's award of attorney fees to the worker (para 7).

Reasons

• Per Jonathan B. Sutin, with Roderick T. Kennedy and Linda M. Vanzi concurring, the court found:
  The worker's offer of judgment was clear and unambiguous as it explicitly called for the application of NMSA 1978, Section 52-1-25.1, which by its plain language entails offsetting and crediting. This statutory reference was deemed sufficient to apprise the employer of its entitlement to credits and offsets (paras 4-5).
  The court disagreed with the employer's contention that the offer was ambiguous and did not provide an appropriate basis for fee-shifting. The offer's explicit call for the application of Section 52-1-25.1, without limitation, unambiguously allowed for crediting and offsetting (para 5).
  The court also addressed the employer's concern regarding ambiguity created by the fee order's reference to Section 52-1-25.1, clarifying that the Workers' Compensation Judge's reference was intended to clarify the basis for the employer's entitlement to offsetting and crediting as implied in the compensation order, further clarifying the basis for the attorney fee award (para 6).