rigorous analysis (New Mexico) · Go Syfert
← New Mexico issues

rigorous analysis in New Mexico

16 New Mexico opinions name it 2 courts 1978–2021 1 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
Brooks v. Norwest Corp.green
nmctapp · 2004 · cited in 6 New Mexico opinions naming this issue, 2006–2018
2 sentences

2018At this stage, "it is essential for the court to understand the substantive law, proof elements of, and defenses to the asserted cause of action to properly assess whether the certification criteria are met." Id. ¶ 31 ; see also Romero v. Philip Morris Inc. , 2005-NMCA-035 , ¶ 38, 137 N.M. 229 , 109 P.3d 768 ("The district court's rigorous analysis often involves considerations that are enmeshed in the factual and legal issues comprising the plaintiff's cause of action." (internal quotation marks and citation omitted) ).

2008The court “must engage in a rigorous analysis of whether the Rule’s requirements have actually been met.” Brooks v. Norwest Corp., 2004-NMCA-134, ¶ 9 , 136 N.M. 599 , 103 P.3d 39 .

36
Amchem Products, Inc. v. Windsorgreen
scotus · 1997 · cited in 5 New Mexico opinions naming this issue, 2004–2007
2 sentences

2007See Amchem, 521 U.S. at 619-20 , 117 S.Ct. 2231 (stating that specifications of Rule 23, which are “designed to protect absentees by blocking unwarranted or overbroad class definitions},] demand undiluted, even heightened, attention in the settlement context”); In re Mego, 213 F.3d at 458 (“Settlements that take place prior to formal class certification require a higher standard of fairness.”); In re GM Trucks, 55 F.3d at 800 (concluding that the lower court’s failure to comply with the Rule 23 certification requirements when certifying a class for settlement “is a plain error of law” and thus

2007See Amchem, 521 U.S. at 619-20 , 117 S.Ct. 2231 (stating that specifications of Rule 23, which are “designed to protect absentees by blocking unwarranted or overbroad class definitions},] demand undiluted, even heightened, attention in the settlement context”); In re Mego, 213 F.3d at 458 (“Settlements that take place prior to formal class certification require a higher standard of fairness.”); In re GM Trucks, 55 F.3d at 800 (concluding that the lower court’s failure to comply with the Rule 23 certification requirements when certifying a class for settlement “is a plain error of law” and thus

35
Ferrell v. Allstate Insurancegreen
nm · 2008 · cited in 3 New Mexico opinions naming this issue, 2009–2012
2 sentences

2012In certifying the class, the district court “must engage in a rigorous analysis of whether the Rule’s requirements have actually been met.” Ferrell, 2008-NMSC-042, ¶ 8 (internal quotation marks and citation omitted). {98} As we stated above, the court certified the class in this case before the MCOs were added as Defendants.

2011In certifying the class, the district court "must engage in a rigorous analysis of whether the Rule's requirements have actually been met." Ferrell, 2008-NMSC-042, ¶ 8 , 144 N.M. 405 , 188 P.3d 1156 (internal quotation marks and citation omitted). {98} As we stated above, the court certified the class in this case before the MCOs were added as Defendants.

23
Romero v. Philip Morris Incorporatedgreen
nmctapp · 2005 · cited in 2 New Mexico opinions naming this issue, 2007–2018
2 sentences

2018At this stage, "it is essential for the court to understand the substantive law, proof elements of, and defenses to the asserted cause of action to properly assess whether the certification criteria are met." Id. ¶ 31 ; see also Romero v. Philip Morris Inc. , 2005-NMCA-035 , ¶ 38, 137 N.M. 229 , 109 P.3d 768 ("The district court's rigorous analysis often involves considerations that are enmeshed in the factual and legal issues comprising the plaintiff's cause of action." (internal quotation marks and citation omitted) ).

2018At this stage, "it is essential for the court to understand the substantive law, proof elements of, and defenses to the asserted cause of action to properly assess whether the certification criteria are met." Id. ¶ 31 ; see also Romero v. Philip Morris Inc. , 2005-NMCA-035 , ¶ 38, 137 N.M. 229 , 109 P.3d 768 ("The district court's rigorous analysis often involves considerations that are enmeshed in the factual and legal issues comprising the plaintiff's cause of action." (internal quotation marks and citation omitted) ).

22
Armijo v. Wal-Mart Stores, Inc.green
nmctapp · 2007 · cited in 2 New Mexico opinions naming this issue, 2009–2018
2 sentences

2009Rather, the court should “engage in a rigorous analysis to determine whether Plaintiffs satisfied the requirements of Rule 1-023.” Id.

2009This is because the district court “must engage in a rigorous analysis of whether the Rule’s requirements have actually been met[,]” Ferrell, 2008-NMSC-042, ¶ 8 (internal quotation marks and citation omitted), and may “probe behind the pleadings [to] forecast what kind of evidence may be required or allowed at trial.” Armijo, 2007-NMCA-120, ¶ 22 (internal quotation marks and citation omitted).

22
In Re American Medical Systems, Inc. Pfizer, Inc.green
ca6 · 1996 · cited in 2 New Mexico opinions naming this issue, 2011–2012
2 sentences

2012The newly added defendant appealed, and the Sixth Circuit held that “[t]he district [court] failed in its duty to conduct a rigorous analysis . . . and clearly abused its discretion.” Id. at 1086 (internal quotation marks omitted).

2011The newly added defendant appealed, and the Sixth Circuit held that "[t]he district [court] failed in its duty to conduct a rigorous analysis ... and clearly abused its discretion." Id. at 1086 (internal quotation marks omitted).

22
cluster 768824green
ca9 · 2000 · cited in 2 New Mexico opinions naming this issue, 2007–2007
2 sentences

2007See Amchem, 521 U.S. at 619-20 , 117 S.Ct. 2231 (stating that specifications of Rule 23, which are "designed to protect absentees by blocking unwarranted or overbroad class definitions[,] demand undiluted, even heightened, attention in the settlement context"); In re Mego, 213 F.3d at 458 ("Settlements that take place prior to formal class certification require a higher standard of fairness."); In re GM Trucks, 55 *778 F.3d at 800 (concluding that the lower court's failure to comply with the Rule 23 certification requirements when certifying a class for settlement "is a plain error of law" and

2007See Amchem, 521 U.S. at 619-20 , 117 S.Ct. 2231 (stating that specifications of Rule 23, which are “designed to protect absentees by blocking unwarranted or overbroad class definitions},] demand undiluted, even heightened, attention in the settlement context”); In re Mego, 213 F.3d at 458 (“Settlements that take place prior to formal class certification require a higher standard of fairness.”); In re GM Trucks, 55 F.3d at 800 (concluding that the lower court’s failure to comply with the Rule 23 certification requirements when certifying a class for settlement “is a plain error of law” and thus

22
cluster 696566green
ca3 · 1995 · cited in 1 New Mexico opinions naming this issue, 2007–2007
1 sentence

2007See Amchem, 521 U.S. at 619-20 , 117 S.Ct. 2231 (stating that specifications of Rule 23, which are “designed to protect absentees by blocking unwarranted or overbroad class definitions},] demand undiluted, even heightened, attention in the settlement context”); In re Mego, 213 F.3d at 458 (“Settlements that take place prior to formal class certification require a higher standard of fairness.”); In re GM Trucks, 55 F.3d at 800 (concluding that the lower court’s failure to comply with the Rule 23 certification requirements when certifying a class for settlement “is a plain error of law” and thus

11
O'Connor v. Boeing North American, Inc.green
cacd · 1998 · cited in 1 New Mexico opinions naming this issue, 2004–2004
1 sentence

2004Amchem Prods., Inc., 521 U.S. at 613-14 , 117 S.Ct. 2231 ; O’Connor v. Boeing N. Am., Inc., 184 F.R.D. 311, 318 (C.D.Cal.1998).

11
cluster 776519green
ca2 · 2001 · cited in 1 New Mexico opinions naming this issue, 2004–2004
1 sentence

2004Eisen v. Carlisle & Jacquelin, 417 U.S. 156, 178 , 94 S.Ct. 2140 , 40 L.Ed.2d 732 (1974) (holding certification is not an occasion for inquiry into the merits); In re Visa Check/MasterMoney Antitrust Litig., 280 F.3d 124, 135 (2d Cir.2001) (noting that despite the rigorous analysis requirement, “a motion for class certification is not an occasion for examination of the merits”) (internal quotation marks and citation omitted). {10} Plaintiffs bear the burden to show that all four prerequisites of Rule 1-023(A) and at least one of the requirements of Rule 1-023(B) are met.

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 (7)

CaseCitedYears
Davis v. Devon Energy Corp. green
nm · 2009
1 sentence

2021“This is because the district court must engage in a rigorous analysis of whether [Rule 1-023’s] requirements have actually been met and may probe behind the pleadings to forecast what kind of evidence may be required or allowed at trial.” Id. (alterations, internal quotation marks, and citation omitted).

12021–2021
Bartlett v. Mirabal green
nmctapp · 2000
2 sentences

2008Plaintiffs, citing Bartlett v. Mirabal, 2000-NMCA-036 , 128 N.M. 830 , 999 P.2d 1062 , argue that federal courts apply a less rigorous standard in granting summary judgment than do New Mexico courts and argue that the district court erred by following the reasoning of the Eleventh Circuit Court of Appeals, which necessarily incorporated a less rigorous federal summary judgment standard. {14} “Prior to 1986, the [United States] Supreme Court sent mixed messages about the availability of the [summary judgment] motion.

2008Plaintiffs, citing Bartlett v. Mirabal, 2000-NMCA-036 , 128 N.M. 830 , 999 P.2d 1062 , argue that federal courts apply a less rigorous standard in granting summary judgment than do New Mexico courts and argue that the district court erred by following the reasoning of the Eleventh Circuit Court of Appeals, which necessarily incorporated a less rigorous federal summary judgment standard. {14} “Prior to 1986, the [United States] Supreme Court sent mixed messages about the availability of the [summary judgment] motion.

12008–2008
Jackson v. Virginia red
scotus · 1979
2 sentences

2007He suggested that “to obtain relief on a claim of actual innocence, the petitioner must show that he probably is innocent.” Id. at 442 , 113 S.Ct. 853 (Blackmun, J., dissenting). {26} The variety of standards advanced by the various opinions in Herrera, is echoed by the states recognizing freestanding claims of actual innocence.

2007He suggested that "to obtain relief on a claim of actual innocence, the petitioner must show that he probably is innocent." Id. at 442 , 113 S.Ct. 853 (Blackmun, J., dissenting). {26} The variety of standards advanced by the various opinions in Herrera , is echoed by the states recognizing freestanding claims of actual innocence.

12007–2007
Herrera v. Collins green
scotus · 1993
2 sentences

2007He suggested that “to obtain relief on a claim of actual innocence, the petitioner must show that he probably is innocent.” Id. at 442 , 113 S.Ct. 853 (Blackmun, J., dissenting). {26} The variety of standards advanced by the various opinions in Herrera, is echoed by the states recognizing freestanding claims of actual innocence.

2007He suggested that "to obtain relief on a claim of actual innocence, the petitioner must show that he probably is innocent." Id. at 442 , 113 S.Ct. 853 (Blackmun, J., dissenting). {26} The variety of standards advanced by the various opinions in Herrera , is echoed by the states recognizing freestanding claims of actual innocence.

12007–2007
Coopers & Lybrand v. Livesay red
scotus · 1978
2 sentences

2005The district court’s rigorous analysis often “involves considerations that are enmeshed in the factual and legal issues comprising the plaintiffs cause of action.” Coopers & Lybrand v. Livesay, 437 U.S. 463, 469 , 98 S.Ct. 2454 , 57 L.Ed.2d 351 (1978) (internal quotation marks, citation, and emphasis omitted).

2005The district court’s rigorous analysis often “involves considerations that are enmeshed in the factual and legal issues comprising the plaintiffs cause of action.” Coopers & Lybrand v. Livesay, 437 U.S. 463, 469 , 98 S.Ct. 2454 , 57 L.Ed.2d 351 (1978) (internal quotation marks, citation, and emphasis omitted).

12005–2005
Eisen v. Carlisle & Jacquelin green
scotus · 1974
2 sentences

2004Eisen v. Carlisle & Jacquelin, 417 U.S. 156, 178 , 94 S.Ct. 2140 , 40 L.Ed.2d 732 (1974) (holding certification is not an occasion for inquiry into the merits); In re Visa Check/MasterMoney Antitrust Litig., 280 F.3d 124, 135 (2d Cir.2001) (noting that despite the rigorous analysis requirement, “a motion for class certification is not an occasion for examination of the merits”) (internal quotation marks and citation omitted). {10} Plaintiffs bear the burden to show that all four prerequisites of Rule 1-023(A) and at least one of the requirements of Rule 1-023(B) are met.

2004Eisen v. Carlisle & Jacquelin, 417 U.S. 156, 178 , 94 S.Ct. 2140 , 40 L.Ed.2d 732 (1974) (holding certification is not an occasion for inquiry into the merits); In re Visa Check/MasterMoney Antitrust Litig., 280 F.3d 124, 135 (2d Cir.2001) (noting that despite the rigorous analysis requirement, “a motion for class certification is not an occasion for examination of the merits”) (internal quotation marks and citation omitted). {10} Plaintiffs bear the burden to show that all four prerequisites of Rule 1-023(A) and at least one of the requirements of Rule 1-023(B) are met.

12004–2004
Conley v. Gibson red
scotus · 1957
2 sentences

1978The United States Supreme Court in Conley v. Gibson, 355 U.S. 41 , 78 S.Ct. 99 , 2 L.Ed.2d 80 (1957) set out a rigorous test for determining whether a complaint fails to state a claim upon which relief may be granted: ...

1978The United States Supreme Court in Conley v. Gibson, 355 U.S. 41 , 78 S.Ct. 99 , 2 L.Ed.2d 80 (1957) set out a rigorous test for determining whether a complaint fails to state a claim upon which relief may be granted: ...

11978–1978

Where else courts name it

TX 182 (1915–2026) IN 129 (1989–2025) CA 99 (1923–2026) OH 96 (1991–2025) LA 80 (1911–2022) NY 67 (1899–2026) IL 64 (1941–2025) OR 62 (1928–2026) FL 46 (1974–2025) NJ 39 (1976–2025) AL 39 (1917–2026) ID 34 (1972–2023) MA 32 (1973–2026) WA 30 (1944–2023) NC 28 (1913–2021) PA 28 (1925–2026) MD 23 (1925–2026) KS 22 (1879–2024) NV 22 (1996–2024) DC 21 (1952–2023) AR 20 (1893–2024) GA 20 (1983–2025) MI 19 (1919–2025) CT 19 (1976–2025) ND 18 (1982–2002) WI 18 (1923–2025) RI 17 (1983–2015) TN 17 (1931–2025) NM 16 (1978–2021) MN 15 (1972–2018) VT 14 (1980–2026) UT 14 (1933–2016) WY 14 (1893–2025) MO 13 (1958–2025) ME 13 (1972–2020) KY 13 (1946–2025) WV 11 (1909–2022) CO 11 (1995–2022) IA 11 (1915–2026) AZ 10 (1981–2026) VA 10 (1906–2020) AK 6 (1972–2011) DE 6 (1989–2026) NH 5 (1990–2018) MT 4 (1900–2016) OK 4 (2007–2023) MS 3 (1998–2018) SD 3 (2003–2013) HI 3 (1981–2009) NE 2 (1897–2004) SC 2 (1989–2018)

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.

← Caselaw search · G Cite Topics · Brief Check