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 92-year-old resident at a skilled nursing facility in Taos, New Mexico, suffered two falls, resulting in a subdural hematoma. The facility had identified her as a high fall risk and implemented a care plan, but allegedly failed to follow it. After the second fall, the resident's condition worsened, leading to emergency surgery. The resident's representative sued the facility for negligence, and a jury awarded $550,000 in damages (paras 2-3, 9).
Procedural History
- District Court, Taos County: Granted Defendant’s motion for a directed verdict on punitive damages and denied Plaintiff’s motion for prejudgment interest (para 1).
Parties' Submissions
- Plaintiff-Appellant: Argued that sufficient evidence was presented for punitive damages based on cumulative conduct and that the district court failed to consider the timeliness and reasonableness of Defendant’s settlement offers when denying prejudgment interest (para 1).
- Defendant-Appellee: [Not applicable or not found]
Legal Issues
- Whether the Plaintiff presented sufficient evidence for the issue of punitive damages to be submitted to the jury.
- Whether the district court properly considered all factors in denying Plaintiff’s motion for prejudgment interest.
Disposition
- The court affirmed the denial of Plaintiff’s motion for prejudgment interest.
- The court reversed the district court’s grant of Defendant’s motion for a directed verdict on the issue of punitive damages (para 1).
Reasons
Per Henderson J. (Duffy and Yohalem JJ. concurring):
The court found that the Plaintiff presented sufficient evidence of the Defendant’s cumulative conduct, which could be considered wanton and reckless, warranting submission of the punitive damages issue to the jury. The evidence included the facility's failure to implement fall prevention measures and adequately respond to the resident's head injury (paras 8-11). On the issue of prejudgment interest, the court held that the district court did not abuse its discretion, as it considered the relevant factors, including delays attributable to the Plaintiff and the disparity in settlement offers (paras 12-17).