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

Two worker-petitioners challenged the attorney fees cap in the New Mexico Workers’ Compensation Act, arguing it infringes on the New Mexico Supreme Court's power to regulate the practice of law. The cap limits attorney fees for representation before the Workers’ Compensation Administration and the courts on appeal to $22,500. Both petitioners had been awarded the maximum attorney fees at the administrative level (paras 1, 10).

Procedural History

• New Mexico Court of Appeals, September 6, 2023: Certified questions to the New Mexico Supreme Court regarding the constitutionality of the attorney fees cap in the Workers’ Compensation Act (para 1).

Parties' Submissions

• Worker-Petitioners: Argued that the attorney fees cap violates the separation-of-powers doctrine by infringing on the Supreme Court's power to regulate the practice of law, including attorney fees (paras 1, 11).
• Employer-Respondents: Contended that the regulation of attorney fees is a matter of substantive law, which falls under the legislative purview, and that the cap is constitutional (paras 29-32).

Legal Issues

• Does the regulation of attorney fees fall within the Supreme Court’s constitutional power to regulate the practice of law?
• Does Section 52-1-54(I) of the Workers’ Compensation Act conflict with the Supreme Court’s rules or precedents?
• Did the 1986 amendment to Article III, Section 1 of the New Mexico Constitution transfer some of the Supreme Court’s authority to regulate the practice of law to the legislative branch in the workers’ compensation context?
• Does the attorney fees cap infringe upon the Supreme Court’s exclusive power to regulate practice and procedure in the courts?

Disposition

• The Supreme Court held that the attorney fees cap in Section 52-1-54(I) is nonbinding on appeals in the courts, as it infringes on the Court’s constitutional power to regulate the practice of law (para 56).
• The ruling is applied with selective prospectivity (para 65).

Reasons

Per Bacon J. (Thomson C.J., Vigil, Vargas, and Zamora JJ. concurring):

• The Court’s constitutional power to regulate the practice of law includes the regulation of attorney fees generally but not within the workers’ compensation context, which is quasi-judicial and falls under legislative purview (paras 21-42).
• Section 52-1-54(I) does not conflict with the Court’s rules or precedents within the workers’ compensation context, as the Court’s authority does not extend there (para 43).
• The 1986 amendment did not transfer any of the Court’s regulatory authority to the Legislature, and judicial review of attorney fee awards in the WCA remains governed by the standard in Harrell, ensuring meaningful review (paras 44-48).
• The attorney fees cap infringes on the Court’s power when applied to appeals in the courts, conflicting with Rule 16-105, which governs reasonable attorney fees (paras 52-56).
• The decision is applied with selective prospectivity due to reliance interests and the need to adhere to separation-of-powers principles (paras 60-65).