Restatement rule (New Mexico) · Go Syfert
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Restatement rule in New Mexico

17 New Mexico opinions name it 2 courts 1916–2024 2 in the last five years

The cases below were cited by New Mexico courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
Stotlar v. Hestergreen
nmctapp · 1978 · cited in 2 New Mexico opinions naming this issue, 2013–2013
2 sentences

2013See Stotlar v. Hester, 1978-NMCA-067 ,¶ 13, 92 N.M. 26 , 582 P.2d 403 (adopting the Restatement standard); see also UJI 13-1632 NMRA, Comm. Commentary.

2013See Stotlar v. Hester, 1978-NMCA-067 ,¶ 13, 92 N.M. 26 , 582 P.2d 403 (adopting the Restatement standard); see also UJI 13-1632 NMRA, Comm. Commentary.

22
Apodaca v. AAA Gas Co.green
nmctapp · 2003 · cited in 1 New Mexico opinions naming this issue, 2022–2022
2 sentences

2022The Restatement standard for abnormally dangerous activities that New Mexico has adopted requires the district court to ascribe to each factor listed above such weight as is warranted based “upon the facts in evidence.” Restatement (Second) of Torts § 520 cmt. l; see also Apodaca, 2003-NMCA-085, ¶ 19 (noting the applicability of the six factors from the Restatement (Second) of Torts § 520).

2022The Restatement standard for abnormally dangerous activities that New Mexico has adopted requires the district court to ascribe to each factor listed above such weight as is warranted based “upon the facts in evidence.” Restatement (Second) of Torts § 520 cmt. l; see also Apodaca, 2003-NMCA-085, ¶ 19 (noting the applicability of the six factors from the Restatement (Second) of Torts § 520).

11
Lancellotti v. Thomasgreen
pa · 1985 · cited in 1 New Mexico opinions naming this issue, 2011–2011
2 sentences

2011See id. at 119-20 .

2011See id. at 119-20 .

11
Harger v. Structural Services, Inc.green
nm · 1996 · cited in 1 New Mexico opinions naming this issue, 2010–2010
2 sentences

2010Rather, the totality of the circumstances should be considered in determining whether the employer has the right to exercise essential control over the work or workers of a particular contractor.” Id. (alteration in original) (quoting Harger v. Structural Servs., Inc., 121 N.M. 657, 667 , 916 P.2d 1324, 1334 (1996)).

2010Rather, the totality of the circumstances should be considered in determining whether the employer has the right to exercise essential control over the work or workers of a particular contractor.” Id. (alteration in original) (quoting Harger v. Structural Servs., Inc., 121 N.M. 657, 667 , 916 P.2d 1324, 1334 (1996)).

11
Dominguez v. Stonegreen
nmctapp · 1981 · cited in 1 New Mexico opinions naming this issue, 2007–2007
2 sentences

2007See Dominguez, 97 N.M. at 214 , 638 P.2d at 426 . 5 .

2007See Dominguez, 97 N.M. at 214 , 638 P.2d at 426 . 5 .

11
Venaglia v. Kropinakgreen
nmctapp · 1998 · cited in 1 New Mexico opinions naming this issue, 2005–2005
2 sentences

2005See Venaglia v. Kropinak, 1998-NMCA-043, ¶¶ 9, 29 , 125 N.M. 25 , 956 P.2d 824 (adopting the Restatement rule that a guarantor of a negotiable instrument is discharged to the extent that the payee impairs the guarantor's recourse against the payor); see also Restatement (Third) of Suretyship and Guaranty § 44 (stating that guarantor can be discharged if the creditor impairs a guarantor's right of restitution from the principal); Restatement (Third) of Suretyship and Guaranty § 50(1) (stating that a creditor's delay or failure to act against the principal does not discharge the guarantor). {21}

2005See Venaglia v. Kropinak, 1998-NMCA-043, ¶¶ 9, 29 , 125 N.M. 25 , 956 P.2d 824 (adopting the Restatement rule that a guarantor of a negotiable instrument is discharged to the extent that the payee impairs the guarantor's recourse against the payor); see also Restatement (Third) of Suretyship and Guaranty § 44 (stating that guarantor can be discharged if the creditor impairs a guarantor's right of restitution from the principal); Restatement (Third) of Suretyship and Guaranty § 50(1) (stating that a creditor's delay or failure to act against the principal does not discharge the guarantor). {21}

11
Abshire v. Stollergreen
illappct · 1992 · cited in 1 New Mexico opinions naming this issue, 1996–1996
2 sentences

1996A managerial employee has been defined “as one who ‘formulates, determines and effectuates his employer’s policies, one with discretion or authority to make ultimate determinations independent of company consideration and approval of’ whether a policy should be adopted.’ ” Id. at 145 , 879 P.2d at 777 (quoting Abshire v. Stoller, 235 Ill.App.3d 849 , 176 Ill.Dec. 559, 565 , 601 N.E.2d 1257, 1263 (1992), appeal denied, 148 Ill.2d 639 , 183 Ill.Dec. 15 , 610 N.E.2d 1259 (1993)). 32.

1996A managerial employee has been defined “as one who ‘formulates, determines and effectuates his employer’s policies, one with discretion or authority to make ultimate determinations independent of company consideration and approval of’ whether a policy should be adopted.’ ” Id. at 145 , 879 P.2d at 777 (quoting Abshire v. Stoller, 235 Ill.App.3d 849 , 176 Ill.Dec. 559, 565 , 601 N.E.2d 1257, 1263 (1992), appeal denied, 148 Ill.2d 639 , 183 Ill.Dec. 15 , 610 N.E.2d 1259 (1993)). 32.

11
Samedan Oil Corp. v. Neeldgreen
nm · 1978 · cited in 1 New Mexico opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., Samedan, 91 N.M. at 601, 603-04 , 577 P.2d at 1245, 1247-48 (Easley, J., dissenting) (implying that Restatement rule of managerial capacity is not applicable in New Mexico).

1994See, e.g., Samedan, 91 N.M. at 601, 603-04 , 577 P.2d at 1245, 1247-48 (Easley, J., dissenting) (implying that Restatement rule of managerial capacity is not applicable in New Mexico).

11
Smith v. PRICE'S CREAMERIES, DIV., ETC.green
nm · 1982 · cited in 1 New Mexico opinions naming this issue, 1985–1985
2 sentences

1985Smith v. Price's Creameries, Division of Creamland Dairies, Inc., 98 N.M. 541, 545 , 650 P.2d 825, 829 (1982).

1985Smith v. Price's Creameries, Division of Creamland Dairies, Inc., 98 N.M. 541, 545 , 650 P.2d 825, 829 (1982).

11
Pedro Rodriquez Bustamante v. Harold J. Cardwell (Frank A. Eyman), Warden, Arizona State Prisongreen
ca9 · 1974 · cited in 1 New Mexico opinions naming this issue, 1980–1980
1 sentence

1980See Bustamante v. Cardwell, 497 F.2d 556 (9th Cir. 1974); Jackson v. Hutto, 508 F.2d 890 (8th Cir. 1975); People v. Musser, 53 Mich.App. 683 , 219 N.W.2d 781 (1974).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Mexico. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
Jackson v. State green
nm · 1983
2 sentences

2024Cf. Hovey, 1986-NMSC-069 , ¶ 13 (holding that the Court of Appeals erred in determining that communications with the jury outside of the defendant’s presence were not prejudicial where the trial court’s answers to the jury’s questions improperly characterized the evidence and limited the scope of the jury’s deliberations). {10} The jury instruction submitted on CSP was based on the UJI and set out the elements of the offense, and the jury was instructed that it had to find each element in order to convict. [RP 213] See UJI 14-956A NMRA; see also State v. Ortega, 2014- NMSC-017, ¶ 32, 327 P.3d

2024Cf. Hovey, 1986-NMSC-069 , ¶ 13 (holding that the Court of Appeals erred in determining that communications with the jury outside of the defendant’s presence were not prejudicial where the trial court’s answers to the jury’s questions improperly characterized the evidence and limited the scope of the jury’s deliberations). {10} The jury instruction submitted on CSP was based on the UJI and set out the elements of the offense, and the jury was instructed that it had to find each element in order to convict. [RP 213] See UJI 14-956A NMRA; see also State v. Ortega, 2014- NMSC-017, ¶ 32, 327 P.3d

12024–2024
Durham v. Guest green
nm · 2009
1 sentence

2020Plaintiffs offer no reason why the Restatement’s framework should be rejected here. {39} Plaintiffs argue that our Supreme Court, in Durham, 2009-NMSC-007, ¶ 29 , “held that lack of probable cause is only a required element for an abuse of process claim that occurs at the initiation of a claim.” But this is incorrect; Durham simply held that a plaintiff alleging a procedural impropriety or wrongful use of proceedings (the second type of misuse of process) need not have initiated judicial proceedings.

12020–2020
Famiglietta v. Ivie-Miller Enterprises, Inc. green
nmctapp · 1998
2 sentences

2011We begin by examining these two cases. {11} In Famiglietta, two sellers sold a tortilla chip distributorship to a buyer in return for a series of installment payments. 1998-NMCA-155, ¶ 1 , 126 N.M. 69 , 966 P.2d 777 .

2011We begin by examining these two cases. {11} In Famiglietta, two sellers sold a tortilla chip distributorship to a buyer in return for a series of installment payments. 1998-NMCA-155, ¶ 1 , 126 N.M. 69 , 966 P.2d 777 .

12011–2011
Solar Age Manufacturing, Inc. v. Employment Security Department neutral
nm · 1986
2 sentences

2010Solar Age Mfg., Inc., 103 N.M. at 781-82 , 714 P.2d at 585-86 .

2010Solar Age Mfg., Inc., 103 N.M. at 781-82 , 714 P.2d at 585-86 .

12010–2010
Albuquerque Concrete Coring Co. v. Pan Am World Services, Inc. green
nm · 1994
2 sentences

1996We adopted the Restatement standard in Albuquerque Concrete, noting that “[w]hen a corporate agent with managerial capacity acts on behalf of the corporation, pursuant to the theoretical underpinnings of the Restatement rule of managerial capacity, his acts are the acts of the corporation; the corporation has participated.” Albuquerque Concrete, 118 N.M. at 146 , 879 P.2d at 778 .

1996We adopted the Restatement standard in Albuquerque Concrete, noting that “[w]hen a corporate agent with managerial capacity acts on behalf of the corporation, pursuant to the theoretical underpinnings of the Restatement rule of managerial capacity, his acts are the acts of the corporation; the corporation has participated.” Albuquerque Concrete, 118 N.M. at 146 , 879 P.2d at 778 .

11996–1996
State v. McClure green
nmctapp · 1980
2 sentences

1986That burden was met in the following: State v. McClure, 94 N.M. 440 , 612 P.2d 232 (Ct.App.1980) (stating that the improper communication was merely a restatement of an instruction previously given); State v. Maes, 81 N.M. 550 , 469 P.2d 529 (Ct.App.1970) (stating that the improper communication was made after the jury was ready to return its verdict).

1986That burden was met in the following: State v. McClure, 94 N.M. 440 , 612 P.2d 232 (Ct.App.1980) (stating that the improper communication was merely a restatement of an instruction previously given); State v. Maes, 81 N.M. 550 , 469 P.2d 529 (Ct.App.1970) (stating that the improper communication was made after the jury was ready to return its verdict).

11986–1986
State v. Maes green
nmctapp · 1970
2 sentences

1986That burden was met in the following: State v. McClure, 94 N.M. 440 , 612 P.2d 232 (Ct.App.1980) (stating that the improper communication was merely a restatement of an instruction previously given); State v. Maes, 81 N.M. 550 , 469 P.2d 529 (Ct.App.1970) (stating that the improper communication was made after the jury was ready to return its verdict).

1986That burden was met in the following: State v. McClure, 94 N.M. 440 , 612 P.2d 232 (Ct.App.1980) (stating that the improper communication was merely a restatement of an instruction previously given); State v. Maes, 81 N.M. 550 , 469 P.2d 529 (Ct.App.1970) (stating that the improper communication was made after the jury was ready to return its verdict).

11986–1986
Langan v. Valicopters, Inc. green
wash · 1977
2 sentences

1980Langan v. Valicopters, Inc., 88 Wash.2d 855 , 567 P.2d 218 (1977).

1980Langan v. Valicopters, Inc., 88 Wash.2d 855 , 567 P.2d 218 (1977).

11980–1980
Samuel S. Jackson v. Terrell Don Hutto, Commissioner, Arkansas Department of Correction green
ca8 · 1975
1 sentence

1980See Bustamante v. Cardwell, 497 F.2d 556 (9th Cir. 1974); Jackson v. Hutto, 508 F.2d 890 (8th Cir. 1975); People v. Musser, 53 Mich.App. 683 , 219 N.W.2d 781 (1974).

11980–1980
People v. Musser green
michctapp · 1974
2 sentences

1980See Bustamante v. Cardwell, 497 F.2d 556 (9th Cir. 1974); Jackson v. Hutto, 508 F.2d 890 (8th Cir. 1975); People v. Musser, 53 Mich.App. 683 , 219 N.W.2d 781 (1974).

1980See Bustamante v. Cardwell, 497 F.2d 556 (9th Cir. 1974); Jackson v. Hutto, 508 F.2d 890 (8th Cir. 1975); People v. Musser, 53 Mich.App. 683 , 219 N.W.2d 781 (1974).

11980–1980
MacLeod v. Tribune Publishing Co. green
cal · 1959
2 sentences

1970Oregon adopted the Restatement rule in Hinkle v. Alexander, supra, without providing an exception like ours, but said: “In support of the libel per quod.rule it is contended by some, and as partially stated by Justice Traynor, in MacLeod v. Tribune Publishing Co., 1959, 52 Cal.2d 536, 550 , 343 P.2d 36, 43-44 , that the per quod rule protects the news media from vexatious actions for trifling claims of libel.

1970Oregon adopted the Restatement rule in Hinkle v. Alexander, supra, without providing an exception like ours, but said: “In support of the libel per quod.rule it is contended by some, and as partially stated by Justice Traynor, in MacLeod v. Tribune Publishing Co., 1959, 52 Cal.2d 536, 550 , 343 P.2d 36, 43-44 , that the per quod rule protects the news media from vexatious actions for trifling claims of libel.

11970–1970
United States v. Cook neutral
· 1909
1 sentence

1916In the case of United States v. Cook, 15 N. M. 124, 103 Pac. 305 , Mr. Chief Justice Mills, of the Territorial Supreme Court, stated the rule.in this regard as follows: “The court has often held that no alleged errors, unless they are jurisdictional, will be considered, except those which ' are set out in the motion for a new trial.” This was but a restatement of the rule laid down in former decisions of the territorial Supreme Court, and has been unformly adhered to by the territorial and state Supreme Court.

11916–1916

Where else courts name it

CA 103 (1909–2025) TX 86 (1927–2026) PA 68 (1901–2026) AZ 55 (1953–2026) NJ 53 (1957–2026) WA 49 (1943–2025) IL 47 (1946–2016) IN 44 (1979–2019) OR 40 (1960–2020) NY 39 (1900–2024) OH 33 (1950–2024) AL 32 (1911–2017) IA 32 (1972–2026) MI 31 (1891–2023) DE 30 (1945–2026) MO 29 (1889–2023) CT 26 (1982–2026) FL 25 (1968–2021) MN 23 (1954–2024) MD 23 (1960–2023) UT 20 (1983–2026) WI 19 (1931–2019) VT 19 (1991–2026) MA 18 (1975–2010) DC 17 (1987–2025) NM 17 (1916–2024) TN 16 (1952–2019) KS 16 (1972–2022) AK 14 (1975–2024) GA 13 (1923–2022) CO 13 (1986–2024) LA 12 (1964–2021) NE 11 (1930–2026) VA 11 (1932–2026) ME 11 (1955–2020) RI 11 (1956–2019) MT 10 (1955–2020) SD 10 (1970–2023) OK 10 (1965–2011) MS 9 (1966–2017) ND 9 (1976–2024) AR 9 (1907–2014) ID 7 (1983–2005) VI 7 (1980–2023) WV 7 (1956–2023) HI 6 (1945–2020) SC 5 (1968–2023) KY 5 (1919–2016) WY 5 (1981–1992) NV 5 (1983–2017) NC 4 (1969–1998) NH 3 (1992–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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