Eavenson v. Lewis Means, Inc.
New Mexico Supreme Court · 1986-12-30 · cited 15×
Marie Eavenson sued Lewis Means, Inc. for breach of an oral promise of employment, claiming she quit her prior job after accepting a higher-paying offer with health insurance but was then refused the position. The trial court granted summary judgment to Means, but the New Mexico Supreme Court reversed and remanded for trial. The court identified genuine issues of material fact on whether promissory estoppel applied, including reasonable reliance, foreseeable detriment, and economic loss. It further held that promissory estoppel could bar Means from invoking the statute of frauds as a defense if the elements were established at trial.
labor & employmentprocedure
Data General Corp. v. Communications Diversified, Inc.
New Mexico Supreme Court · 1986-11-21
Data General sued Communications Diversified to recover recalculated discounts under a 1978 agreement that provided price discounts on future computer purchases if a minimum quantity was bought within fifteen months. The trial court granted summary judgment to the defendant, ruling that the agreement was a contract for the sale of goods governed by the UCC's four-year statute of limitations, which had expired. The New Mexico Supreme Court reversed, holding that the agreement was not a contract for the sale of goods because it involved no specific equipment, passed no title for a price, and imposed no obligation to purchase any units. The court determined that the six-year general contract statute of limitations applied instead, the breach occurred the day after the agreement's term ended in June 1979 when the minimum was not met, and the 1983 lawsuit was therefore timely.
business & regulatoryprocedure
State v. Summerall
New Mexico Supreme Court · 1986-10-30 · cited 10×
In State v. Summerall, the defendant was convicted of residential burglary and conspiracy to commit residential burglary after a co-defendant testified under a grant of immunity that improperly included protection from perjury charges. The Court of Appeals reversed the conviction, finding plain error in the defective immunity order, but the New Mexico Supreme Court reversed that decision and reinstated the conviction. The Court held that plain error requires a showing of prejudice to the defendant, which was absent here because the co-defendant's testimony was entirely exculpatory and did not contribute to the conviction. The opinion also clarified that the relevant immunity statute applies only to grand jury proceedings, not trials.
criminal lawprocedure
State v. Compton
New Mexico Supreme Court · 1986-10-22 · cited 34×
The case involved Joel Lee Compton, who was convicted of capital murder for killing a police officer and aggravated assault after an altercation at a motel in Albuquerque. Compton was sentenced to death and appealed on multiple grounds, including the admissibility of his wife's testimony despite a claimed spousal privilege, alleged improper prosecutorial arguments during the penalty phase, various challenges to the constitutionality of New Mexico's death penalty statutes and procedures, and issues related to jury instructions and death qualification of the jury. The New Mexico Supreme Court affirmed the convictions and death sentence, holding that the wife's testimony was properly admitted, any errors in the penalty phase arguments were harmless, the death penalty scheme was constitutional, and the evidence supported the aggravating circumstance of killing a peace officer. The court reasoned that statutory requirements were met, no fundamental error occurred, and proportionality and other reviews did not warrant reversal.
criminal lawprocedure
Brannock v. Brannock
New Mexico Supreme Court · 1986-06-30 · cited 26×
In Brannock v. Brannock, the petitioner sued her former spouse in district court to collect past-due child support arrearages. The district court found that the parties had entered into an agreement under which the petitioner waived her claim to arrearages in exchange for the respondent's promise to make ongoing monthly payments of $100, dismissed the petition, and reduced the amount of future support; the Court of Appeals affirmed. On certiorari, the New Mexico Supreme Court upheld the judgment, holding that the evidence supported a valid waiver of the reimbursement right because it was supported by consideration and did not impair the children's independent right to support. The Court noted that modification of future support requires a substantial change in circumstances but concluded that the issue had not been preserved on appeal, so the district court's order stood.
family law
State v. Pothier
New Mexico Supreme Court · 1986-06-23 · cited 22×
In State v. Pothier, two defendants charged with first-degree murder each gave statements to police implicating the other; when called as witnesses in the other's separate trial, they invoked the Fifth Amendment, were granted use immunity, and still refused to testify, leading the trial court to declare mistrials and try them for direct criminal contempt. The district court convicted each of contempt after jury trials and imposed life sentences. On appeal, the New Mexico Supreme Court affirmed the convictions, holding that direct contempt does not require a preliminary hearing, that the evidence was sufficient, that defenses and jury instructions were properly handled, and that other procedural claims lacked merit; it reversed only the sentences, finding life imprisonment an abuse of discretion because contempt is sui generis, comparable New Mexico cases imposed far shorter terms, and no other state allows imprisonment longer than one year for the offense. The case was remanded for resentencing.
criminal lawprocedure