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 Plaintiff, Four Winds Behavioral Health, Inc., provides behavioral health services to New Mexico Medicaid recipients through contracts with the New Mexico Human Services Department (HSD). In April 2017, HSD approved Plaintiff's application to provide intensive outpatient services (IOP), which were to be reimbursed based on fifteen-minute units. However, in December 2017, HSD directed that IOP services should be reimbursed in one-hour units at the same dollar amount per unit, contrary to the initial agreement. The Plaintiff filed a federal suit against HSD, which was voluntarily dismissed without prejudice, and subsequently filed a state suit asserting claims for breach of contract and seeking a declaratory judgment (paras 2-4).

Procedural History

• Federal district court, March 14, 2018: Plaintiff filed suit against HSD asserting claims for equitable estoppel and detrimental reliance and seeking a declaratory judgment. The suit was voluntarily dismissed without prejudice on August 14, 2019 (para 3).
• District Court of Santa Fe County, February 13, 2020: Plaintiff initiated a suit in state district court asserting claims for breach of contract and declaratory judgment. HSD's motion to dismiss was denied due to their failure to appear at the hearing. Nearly a year later, HSD filed a motion for summary judgment, which was granted by the district court (paras 4-5).

Parties' Submissions

• Plaintiff: Argued that the two-year statute of limitations for suits on government contracts was tolled by the savings statute during the time the Federal Suit was pending. Also contended that HSD changed the agreed-upon reimbursement rates for IOP services, constituting a breach of contract (paras 2, 4).
• Defendant (HSD): Asserted that Plaintiff’s claims were barred by the two-year statute of limitations on claims based on a written contract with a governmental entity. Argued that the statute of limitations was not tolled under the savings statute because Plaintiff had been negligent in prosecuting the Federal Suit (paras 4-5).

Legal Issues

• Whether the two-year statute of limitations for suits on government contracts was tolled by the savings statute during the pendency of a related federal suit.
• Whether the Plaintiff was negligent in prosecuting the Federal Suit, affecting the tolling of the statute of limitations.
• Whether the Plaintiff's claim for declaratory judgment was subject to the two-year statute of limitations for suits against a government agency based on contract.

Disposition

• The district court's grant of summary judgment in favor of Defendant, the New Mexico Department of Human Services, was affirmed. The court found that the two-year statute of limitations on claims against a governmental entity based on contract had run, and the savings statute did not apply to toll the statute of limitations for the Plaintiff's action (para 5).

Reasons

• The Court of Appeals, per Judge Pro Tem Black, concluded that the savings statute, Section 37-1-14, does not apply to actions brought against the state under Section 37-1-23, which imposes a two-year statute of limitations for suits on government contracts. The court also noted that Plaintiff preserved no alternative issue involving equitable tolling. The court affirmed the district court's decision on the basis that the statute of limitations for Plaintiff's breach of contract claim was not tolled under the savings clause, irrespective of whether Plaintiff was negligent in prosecuting the Federal Suit. Additionally, the court held that the Plaintiff's claim for declaratory judgment was subject to the two-year statute of limitations as it was based on a valid written contract with a governmental agency (paras 6-14).