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Martinez v. Friede2/20/2004
n order expressly disposing of the motion or the date of any automatic denial." Therefore, despite the fact that the district court was still contemplating whether to grant a new trial on damages to Petitioner, the parties had thirty days from the date Petitioner's motion for new trial was automatically denied, September 9, 1999, to timely file a notice of appeal if they so desired. The district court's power to reopen judgment and grant a new trial pursuant to Rule 1-060(B) had no effect on the parties' ability to calculate the time in which they must file their notice of appeal. This is because a motion under Rule 1-060(B) "does not affect the finality of a judgment or suspend its operation." Rule 1-060(B)(6). Therefore, a district court's decision to grant relief "will not affect the time for filing an appeal" nor "interfere with the appellate court's timely disposition of the appeal." Archuleta, 108 N.M. at 548, 775 P.2d at 750.
We agree with the Colorado Supreme Court that "the [district court] has ample powers under [Rule 1-060(B)] to set aside the judgment without unduly expanding the contours of the rule or undercutting the beneficial purposes of [Rule 1-059(D)]." Canton Oil, 731 P.2d at 695. To the extent Dozier can be read, as the Court of Appeals reasoned, to preclude a district court from acting under Rule 1-060(B) because a motion for new trial had been previously denied by operation of law, it is expressly overruled. The main holding of Dozier remains valid: that relief is disfavored under Rule 1-060 if the grounds for the relief were known to the movant in time to bring a motion under Rule 1-059. 118 N.M. at 71-72, 878 P.2d at 1020-21. That holding does not undercut the jurisdiction of the trial court to grant relief on its own motion under Rule 1-060. The Court of Appeals erred in this case by holding that the district court lacked jurisdiction to grant a new trial under Rule 1-060(B).
IV.
Next, we must determine whether the district court properly exercised its discretion in reopening judgment and granting Petitioner a new trial on damages. We generally review the district court's grant of relief under Rule 1-060(B) for an abuse of discretion, see Meiboom v. Watson, 2000-NMSC-004, 29, 128 N.M. 536, 994 P.2d 1154, except in those instances where the issue is one of pure law, see Dozier, 118 N.M. at 71, 878 P.2d 1020. Since the determination of whether a jury was confused by its instructions is factual in nature, we will review the district court's decision to reopen judgment and grant a new trial for abuse of discretion. To reverse the district court under an abuse-of-discretion standard, "it must be shown that the court's ruling exceeds the bounds of all reason . . . or that the judicial action taken is arbitrary, fanciful, or unreasonable." Meiboom, 2000-NMSC-004, 29 (quotation marks and quoted authority omitted) (omission in original); accord United Salt Corp. v. McKee, 96 N.M. 65, 68, 628 P.2d 310, 313 (1981).
Rule 1-060(B)(6) provides that the court may relieve a party from a final judgment for "any other reason justifying relief from the operation of the judgment." We have stated that "Rule 1-060(B)(6) is designed to apply only to exceptional circumstances, which, in the sound discretion of the trial judge, require an exercise of a `reservoir of equitable power' to assure that justice is done." Stein, 1998-NMSC-040, 17. In this regard, Rule 1-060(B)(6) should be "liberally applied" to further the ends of justice. See Koppenhaver v. Koppenhaver, 101 N.M. 105, 109, 678 P.2d 1180, 1184 (Ct. App. 1984).
The jury in this case found Respondent wholly liable for the accident, yet failed to award her any damages for pain and suff
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