Ferlic v. Lovelace Health Sys., LLC

CourtNew Mexico Supreme Court
DecidedJune 8, 2026
StatusPublished

This text of Ferlic v. Lovelace Health Sys., LLC (Ferlic v. Lovelace Health Sys., LLC) is published on Counsel Stack Legal Research, covering New Mexico Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ferlic v. Lovelace Health Sys., LLC, (N.M. 2026).

Opinion

The slip opinion is the first version of an opinion released by the Chief Clerk of the Supreme Court. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Chief Clerk for compliance with Rule 23- 112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion. 1 IN THE SUPREME COURT OF THE STATE OF NEW MEXICO

2 Opinion Number:

3 Filing Date: June 8, 2026

4 NO. S-1-SC-40580

5 KATHERINE FERLIC, as the Personal 6 Representative of the Estate of 7 PAMELA SMITH, deceased,

8 Plaintiff-Respondent,

9 v.

10 LOVELACE HEALTH SYSTEM, LLC, 11 a New Mexico limited liability company, 12 d/b/a Lovelace Medical Center, 13 d/b/a Lovelace Medical Group,

14 Defendant-Petitioner,

15 and

16 AHS MANAGEMENT COMPANY, INC., 17 a Tennessee corporation,

18 Defendant.

19 ORIGINAL PROCEEDING ON CERTIORARI 20 Kathleen McGarry Ellenwood, District Judge

21 Holland & Hart LLP 22 Larry J. Montaño 23 Santa Fe, NM 1 Rodey, Dickason, Sloan, Akin & Robb 2 Paul R. Koller 3 Albuquerque, NM

4 for Petitioner

5 McGinn, Montoya, Love, Curry, & Sievers, PA 6 Kathleen J. Love 7 Katie Curry 8 Albuquerque, NM

9 for Respondent

10 Sutin, Thayer & Browne APC 11 Deborah E. Mann 12 Albuquerque, NM

13 for Amicus Curiae New Mexico Hospital Association

14 Martinez, Hart, Sanchez & Romero, PC 15 Julio C. Romero 16 Albuquerque, NM

17 Vigil Law Firm, PA 18 Alexandra Cervantes 19 Albuquerque, NM

20 New Mexico Trial Lawyers Association 21 David J. Stout 22 Albuquerque, NM

23 for Amicus Curiae New Mexico Trial Lawyers Association 1 OPINION

2 THOMSON, Justice.

3 {1} When the Legislature enacted the New Mexico Medical Malpractice Act (the

4 MMA or the Act) in 1976, it sought to create a balanced system of benefits and

5 burdens for health care providers and patients alike, all with the goal of ensuring the

6 availability of quality providers in New Mexico. See NMSA 1978, §§ 41-5-1 to -29

7 (1976, as amended through 2026); 1 § 41-5-2 (1976) (repealed 2021, effective Jan. 1,

8 2022) (stating the Act’s purpose, “to promote the health and welfare of the people

9 of New Mexico by making available professional liability insurance for health care

10 providers in New Mexico”); Baker v. Hedstrom, 2013-NMSC-043, ¶¶ 17-21, 309

11 P.3d 1047. One statutorily created benefit is the promise of a damages cap in

12 malpractice claims levied against health care providers who have taken the steps to

13 become qualified health care providers (QHPs). Section 41-5-5 (1992) (setting out

14 the requirements to be a QHP under the MMA); Section 41-5-6(A)-(B) (1992)

15 (“Except for punitive damages and medical care and related benefits, the aggregate

1 In 2021, the Legislature made numerous amendments to the MMA; several of those amendments took effect in mid-2021. See § 41-5-14. Those amendments became effective either in July 2021 or in 2022 and do not apply to this case, which arose from events occurring in March of 2021. Accordingly, all references to the MMA in this opinion refer to enactments or amendments made prior to the 2021 amendments of the MMA. 1 dollar amount recoverable by all persons for or arising from any injury or death to a

2 patient as a result of malpractice shall not exceed five hundred thousand dollars

3 ($500,000) per occurrence.”).

4 {2} Pamela A. Smith died in the care of Lovelace Health System, LLC (Lovelace)

5 on April 18, 2021 after undergoing surgery on March 29, 2021 at Lovelace Medical

6 Center in Albuquerque, New Mexico. The wrongful death Estate of Pamela Smith

7 (Plaintiff) filed both direct negligence claims against Lovelace and vicarious liability

8 claims against Lovelace based on the conduct of its employed registered nurses in

9 caring for Ms. Smith. Lovelace was a QHP under the MMA; its employed registered

10 nurses were not, nor were they eligible for qualification under the version of the Act

11 in effect. See § 41-5-3(A) (1977); § 41-5-5 (1992). In this opinion we determine

12 whether a QHP enjoys the benefits of the MMA in vicarious liability claims based

13 on the conduct of its non-QHP employed registered nurses. 2

14 {3} Lovelace presents two questions in this appeal: (1) does Lovelace enjoy the

15 benefits of the MMA in vicarious liability actions for the conduct of its employed

16 registered nurses; and (2) are providers whose practice is not enumerated as eligible

2 The remaining citations to Section 41-5-3 and one citation to Section 41-5-5 in this opinion omit the applicable date parentheticals: (1977) and (1992) respectively. 1 to become a QHP under the MMA, but whose employer is a QHP hospital, entitled

2 to the MMA’s benefits?

3 {4} We hold that the plain language of the MMA demonstrates that the Act covers

4 vicarious liability claims against QHPs based on the acts of a nurse employee who

5 commits malpractice under the Act. See § 41-5-3(C) (defining malpractice claim

6 under the MMA). Because our holding resolves the issue of the MMA’s applicability

7 to Lovelace with respect to the pending vicarious liability claims against it, and

8 because the second question goes to the rights of individuals not a party to this case,

9 we decline to address the second question raised.

10 {5} We recognize that the parties raised a host of arguments regarding how the

11 Legislature’s 2021 amendments to the MMA ought to shape our interpretation of the

12 provisions at issue here—all originally enacted in 1976 or 1992. We will not attempt

13 to divine Legislative intent from amendments passed decades after the Legislature

14 originally drafted, debated, and enacted the pertinent provisions of the MMA,

15 particularly where the Act’s plain language resolves the issue before us.

16 I. BACKGROUND AND PROCEDURAL HISTORY

17 {6} At the time of Ms. Smith’s death, the MMA did not list registered nurses in

18 the definition of “health care provider.” Section 41-5-3(A). Accordingly, Plaintiff

19 sought summary judgment on the MMA’s applicability to the claims arising from 1 Lovelace’s employed registered nurses’ conduct. Plaintiff argued that the plain

2 language of the MMA precludes nurses from becoming QHPs, and, therefore, the

3 MMA does not apply to vicarious liability claims rooted in their conduct. The district

4 court agreed and granted summary judgment, concluding that “[r]egistered nurses

5 are not categorically qualified to be qualified healthcare providers under the Medical

6 Malpractice Act” and, therefore, Lovelace “is not entitled to the benefit and

7 protections of the Medical Malpractice Act with respect to the conduct of its nurse

8 employees.” Lovelace sought certification for interlocutory appeal of the district

9 court’s conclusion, which the district court granted. The Court of Appeals denied

10 interlocutory review; this Court then granted certiorari. Order Denying Application

11 for Interlocutory Appeal, Ferlic v. Lovelace Health Sys., LLC, A-1-CA-41966 (N.M.

12 Ct. App. Aug. 26, 2024); Writ of Certiorari, Ferlic v. Lovelace Health Sys., LLC, S-

13 1-SC-40580 (N.M. Nov. 20, 2024).

14 II. DISCUSSION

15 A. Standard of Review

16 {7} “This Court’s review of orders granting or denying summary judgment is de

17 novo.” Zamora v. St. Vincent Hosp., 2014-NMSC-035, ¶ 9, 335 P.3d 1243. We also

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Ferlic v. Lovelace Health Sys., LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ferlic-v-lovelace-health-sys-llc-nm-2026.