Martinez v. Melloy Brothers, Inc.

CourtNew Mexico Court of Appeals
DecidedSeptember 18, 2025
StatusUnpublished

This text of Martinez v. Melloy Brothers, Inc. (Martinez v. Melloy Brothers, Inc.) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Martinez v. Melloy Brothers, Inc., (N.M. Ct. App. 2025).

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 COURT OF APPEALS OF THE STATE OF NEW MEXICO

2 Opinion Number:__________

3 Filing Date: September 18, 2025

4 No. A-1-CA-41818

5 KARAH MARTINEZ and DAVID 6 MARTINEZ, on their own behalf and 7 on behalf of all others similarly 8 situated,

9 Plaintiffs-Appellees,

10 v.

11 MELLOY BROTHERS, INC., 12 d/b/a MELLOY NISSAN,

13 Defendant-Appellant.

14 Consolidated with

15 KARAH MARTINEZ and DAVID 16 MARTINEZ, on their own behalf and 17 on behalf of all others similarly 18 situated,

19 Plaintiffs-Appellants,

20 v.

21 MELLOY BROTHERS, INC., 22 d/b/a MELLOY NISSAN,

23 Defendant-Appellee.

24 APPEAL FROM THE DISTRICT COURT OF BERNALILLO COUNTY 25 Daniel E. Ramczyk, District Court Judge 1 Feferman, Warren & Mattison 2 Susan Warren 3 Nicholas Mattison 4 Albuquerque, NM

5 for Appellees

6 Atkinson, Baker, Rodriguez, P.C. 7 Justin D. Rodriguez 8 Clifford K. Atkinson 9 Owen E. Barcala 10 Albuquerque, NM

11 Wright Close & Barger, LLP 12 Jessica Z. Barger 13 Brian J. Cathey 14 Houston, TX

15 for Appellant 1 OPINION

2 DUFFY, Judge.

3 {1} The formal opinion filed on June 17, 2025, is hereby withdrawn and the

4 following opinion is substituted. In this consolidated appeal, Plaintiffs challenge the

5 district court’s order granting Defendant Melloy Brothers Inc., d/b/a Melloy

6 Nissan’s motion to compel arbitration, and Defendant challenges the district court’s

7 stay of arbitration pending appeal. This is the second appeal related to this motion,

8 and regrettably, we anticipate that our reversal and remand means that we are likely

9 to see this case again.

10 {2} We provide a comprehensive discussion of the procedural history in this case

11 to highlight the procedural issues that can arise when a party resists arbitration on

12 unconscionability grounds, thus triggering the two-step process described in Peavy

13 v. Skilled Healthcare Grp., Inc., 2020-NMSC-010, ¶ 21, 470 P.3d 218. As for the

14 issues raised in this appeal, because the district court did not decide whether three

15 provisions previously determined by the district court to be facially unconscionable

16 were fair and reasonable, contrary to Rojas v. Reliable Chevrolet (NM), LLC, 2024-

17 NMCA-003, ¶ 10, 539 P.3d 1253, we are unable to review Plaintiffs’ appellate

18 arguments on the merits. We reverse and write only to address the procedure that

19 should be followed on remand. 1 BACKGROUND

2 {3} This case began on November 3, 2020, when Plaintiffs filed a consumer

3 protection class action lawsuit against Defendant for violations of the Unfair

4 Practices Act (UPA), NMSA 1978 §§ 57-12-1 to -26 (1967, as amended through

5 2019), and for unjust enrichment. Plaintiffs alleged that Defendant imposed illegal

6 charges when selling new vehicles and failed to make timely payments on trade-in

7 vehicles. Defendant responded to Plaintiffs’ complaint by filing a motion to compel

8 arbitration, citing an arbitration clause in a “Buyer’s Order Agreement” that

9 Plaintiffs signed when purchasing a vehicle from Defendant. A copy of the Buyer’s

10 Order Agreement is attached hereto as Appendix A and will be referred to as “the

11 Agreement” throughout the remainder of this opinion. The Agreement contains

12 multiple provisions, including a specific arbitration clause.

13 {4} Plaintiffs opposed arbitration on grounds that the arbitration agreement was

14 substantively unconscionable, and therefore unenforceable. Specifically, Plaintiffs

15 identified three provisions of the Agreement they claimed were part of the agreement

16 to arbitrate and argued why each was unfairly one-sided or otherwise violative of

17 public policy. First, Plaintiffs argued that the Agreement contains a limitation on

18 damages provision under the heading, “WARRANTY INFORMATION,” which

19 states:

20 DEALER IS NOT LIABLE FOR INCIDENTAL, 21 CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING OUT OF 1 THIS SALE OR THE USE OF THIS VEHICLE, INCLUDING BUT 2 NOT LIMITED TO LOSS OF USE, LOSS OF TIME, 3 INCONVENIENCE, TRANSPORTATION, RENTAL, LOSS OF 4 EARNINGS OR PROFITS, OR ANY COMMERCIAL LOSS.

5 Plaintiffs asserted that the limitation on damages provision was unfair and one-sided.

6 {5} Second, Plaintiffs argued that the Agreement limits the statute of limitations

7 for their UPA claim to one year under paragraph 10 of the “Additional Terms,”

8 which states, “Any legal claim arising from this transaction must be brought within

9 one year after the date a cause of action accrues, or it will be forever barred.”

10 Plaintiffs argued this provision was unconscionable as contrary to public policy.

11 {6} Third, Plaintiffs contended that the arbitration clause set forth in paragraph 14

12 of the “Additional Terms” was unfairly one-sided because it required the parties to

13 abide by the rules of the American Arbitration Association (AAA):

14 Any dispute between Buyer and Dealer arising out of this transaction 15 will be decided by arbitration in the City of Albuquerque, New Mexico 16 under the New Mexico Uniform Arbitration Act and the applicable 17 rules of the American Arbitration Association. Any arbitration award 18 may be enforced as provided by law. Buyer and Dealer waive any right 19 to a jury trial.

20 Plaintiffs argued that the AAA rules impose significant costs on a class-action

21 plaintiff, making the cost of arbitration prohibitively expensive.

22 {7} Defendant’s reply focused solely on the first step of the Peavy analysis,

23 arguing that the Agreement was bilateral and not facially unconscionable. See Peavy,

24 2020-NMSC-010, ¶¶ 20-21 (“First, the court should analyze the arbitration 1 agreement on its face . . . to determine the legality and fairness of the contract terms

2 themselves. . . . Second, if the court determines the arbitration agreement is facially

3 one-sided, the court should allow the drafting party to present evidence that justifies

4 the agreement is fair and reasonable, such that enforcement of the agreement would

5 not be substantively unconscionable.” (internal quotation marks and citation

6 omitted)). Defendant never argued in the alternative that the one-sidedness of the

7 provisions identified by Plaintiffs were justified as fair and reasonable under Peavy

8 step two. Likewise, Defendant did not request an evidentiary hearing to present

9 evidence that the challenged provisions were fair and reasonable.

10 {8} After briefing but without a hearing, the district court entered an opinion and

11 order denying Defendant’s motion to compel. The court determined that while the

12 arbitration clause itself was neutral on its face, the damages limitation and time-to-

13 sue provisions were unfairly and unreasonably one-sided and unconscionable. The

14 district court found that the damages limitation “limits Plaintiffs’ ability to collect

15 incidental, consequential and punitive damages. Defendant is not so limited,

16 resulting in an unfairly one-sided contract.” Continuing, the district court found that

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Martinez v. Melloy Brothers, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/martinez-v-melloy-brothers-inc-nmctapp-2025.