This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
In September 2019, the Plaintiff and his life partner, Janet Lamkin, visited Taos Diner, where Ms. Lamkin slipped, fell, and sustained injuries that led to her death. The Estate of Ms. Lamkin settled all claims with Taos Diner and Farmers Insurance Exchange. The Plaintiff later filed a lawsuit alleging various claims, including negligence and loss of consortium, against Taos Diner and others (paras 2-3).
Procedural History
- District Court of Bernalillo County: The court granted the Defendants' motion to enforce the settlement agreement against the Plaintiff, dismissing his claims with prejudice (para 1).
Parties' Submissions
- Plaintiff: Argued that the district court erred in enforcing the settlement agreement against him because he was not a party to it, and his claims for loss of consortium and negligent infliction of emotional distress are separate from the Estate’s wrongful death claim (para 3).
- Defendants (Taos Diner and Farmers): Asserted that extrinsic evidence showed the parties intended to include the Plaintiff in the settlement agreement, thus binding him to it (para 3).
Legal Issues
- Whether the district court erred in enforcing the settlement agreement against the Plaintiff, who was not a party to the agreement.
- Whether the Plaintiff's claims for loss of consortium and negligent infliction of emotional distress were extinguished by the settlement agreement (para 3).
Disposition
- The Court of Appeals reversed the district court's decision and remanded the case for further proceedings (para 10).
Reasons
Per Henderson J. (Duffy and Wray JJ. concurring):
The Court found that the settlement agreement was unambiguous and did not include the Plaintiff as a party. The language of the agreement only released claims held by the Estate and its beneficiaries, not the Plaintiff's independent claims. The Plaintiff was not named in the agreement, nor was he a statutory beneficiary of the Estate. The Court also determined that the Plaintiff's claims for loss of consortium and negligent infliction of emotional distress were independent and not extinguished by the agreement, as they belonged to him and not the Estate (paras 6-9).