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 class of pharmacists and pharmacies participating in the New Mexico Medicaid program alleged that they were not properly reimbursed for filling Medicaid recipients' prescriptions under the Public Assistance Act. The dispute arose over whether managed care organizations (MCOs) were required to comply with statutory reimbursement provisions (paras 3-4).

Procedural History

• District Court, October 20, 1999: Granted class certification to the plaintiffs (para 3).
• District Court, June 2000: Granted partial summary judgment in favor of the plaintiffs, holding that the statutory reimbursement provision was mandatory and applied to Medicaid managed care (para 3).
• District Court, September 24, 2003: Denied the MCOs' motions to decertify the class and issued a "new class certification order" (paras 3-4).

Parties' Submissions

• Appellants (MCOs): Argued that the new class certification order met the criteria for appellate review under Rule 1-023(F); that the district court's order violated their constitutional rights; and that the plaintiffs failed to meet the requirements for class certification under Rule 1-023 (para 5).
• Appellees (Plaintiffs): [Not applicable or not found]

Legal Issues

• Whether Rule 1-023(F) NMRA, which allows discretionary appeals of class certification decisions, applies to a case filed before the rule's effective date but involving parties added after the rule's enactment.

Disposition

• The Court of Appeals dismissed the appeal, holding that Rule 1-023(F) did not apply because the case was "pending" at the time the rule became effective (para 18).

Reasons

Per Bustamante CJ (Alarid and Fry JJ. concurring):

• Interpretation of "Pending Case": The Court held that under Article IV, Section 34 of the New Mexico Constitution, a case is considered "pending" from the time it is filed until it is finally resolved. The addition of new parties does not alter the "pending" status of the case (paras 7-9).
• Applicability of Rule 1-023(F): The Court found that Rule 1-023(F), which became effective after the case was filed, could not apply because it would constitute a procedural change affecting a pending case, which is prohibited by the Constitution (paras 10-11).
• Consistency in Procedure: Allowing different procedural rules to apply to different parties in the same case would create inconsistency and undermine the purpose of Article IV, Section 34, which aims to ensure uniformity in procedural rules during litigation (paras 12-15).
• Rejection of MCOs' Arguments: The Court rejected the MCOs' argument that the rule's application to them would not violate the Constitution, emphasizing that the procedural change was not de minimis and would disrupt the consistency of litigation procedures (paras 14-15).
• Federal Case Law Inapplicability: The Court noted that federal case law was not relevant because there is no federal counterpart to Article IV, Section 34 of the New Mexico Constitution (para 17).

The Court concluded that it lacked jurisdiction to hear the appeal under Rule 1-023(F) and dismissed the case (para 18).