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 case involves a child, Corey T., who has been in the custody of the Children, Youth & Families Department (CYFD) since 2015 due to neglect and abuse. Corey has experienced multiple hospitalizations and disruptions in placement. An emergency motion was filed to join Presbyterian Health Plan, Inc. (PHP) and the New Mexico Human Services Department (HSD) as necessary parties to ensure proper discharge planning and provision of medically necessary services, including treatment foster care (paras 3-5).
Procedural History
- Children's Court, December 4, 2023: The children's court granted the emergency motion to join PHP and HSD as necessary parties under Rule 10-121(B)(4) (paras 8-9).
- Court of Appeals: Denied PHP's interlocutory appeal (para 10).
Parties' Submissions
- Petitioner (PHP): Argued that Rule 10-121(B)(4) was too broad and that PHP should not be joined as it had no contractual obligations to the child and that Rule 1-019 was not applicable in children's court (paras 6, 21).
- Respondent (Child): Argued that PHP and HSD were necessary parties due to their legal obligations to the child, which included discharge planning and providing necessary services. The child asserted that complete relief could not be granted without their involvement (paras 5, 22).
Legal Issues
- Whether Rule 10-121(B)(4) allows the children's court to join any person as a party to neglect or abuse proceedings.
- What limiting principle, if any, should apply to Rule 10-121(B)(4) for a children's court determining joinder (paras 11-12).
Disposition
- The Supreme Court of New Mexico held that Rule 10-121(B)(4) must incorporate the necessary-party standard from Rule 1-019(A)(1) to avoid absurd results and remanded the case for the children's court to apply this standard (paras 2, 25).
Reasons
Per Bacon J. (Thomson C.J., Vigil, Vargas, and Zamora JJ. concurring):
The court found that the plain language of Rule 10-121(B)(4) was overly broad and could lead to absurd results if applied without limitation. The court emphasized the importance of serving the best interests of the child and concluded that a limiting principle was necessary. The court decided to incorporate the necessary-party standard from Rule 1-019(A)(1), which requires that a person be joined if complete relief cannot be accorded among those already parties. This standard balances the need to serve the child's best interests while avoiding absurd results (paras 14-23).