McAneny v. Catechis

CourtNew Mexico Court of Appeals
DecidedMarch 30, 2023
StatusUnpublished

This text of McAneny v. Catechis (McAneny v. Catechis) 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
McAneny v. Catechis, (N.M. Ct. App. 2023).

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: March 30, 2023

4 No. A-1-CA-38115

5 BARBARA MCANENY, M.D.; WILLIAM 6 RITCHIE, M.D.; and WILLIAM LIAKOS, 7 JR., M.D.,

8 Plaintiffs-Appellees,

9 and

10 ALBERT KWAN, M.D.,

11 Withdrawn Plaintiff,

12 v.

13 JENNIFER A. CATECHIS, in her capacity 14 as New Mexico Interim Superintendent of 15 Insurance; and the NEW MEXICO OFFICE OF 16 THE SUPERINTENDENT OF INSURANCE,

17 Defendants-Appellants,

18 and

19 RADIOLOGICAL ASSOCIATES OF 20 ALBUQUERQUE, PA; JESSICA WILLIAMS, 21 M.D.; CRAIG LASTINE, M.D.; THRETHA 22 REDDY, M.D.; ADAM DELU, M.D.; CRAIG 23 LANCE, M.D.; and THE DOCTORS 24 COMPANY,

25 Intervenors-Appellants. 1 APPEAL FROM THE DISTRICT COURT OF SANTA FE COUNTY 2 David K. Thomson, District Court Judge

3 Marshall Law, P.C. 4 Stephen R. Marshall 5 Albuquerque, NM

6 Hunt Law Firm 7 Lee R. Hunt 8 Cynthia L. Zedalis 9 Santa Fe, NM

10 Stephen Durkovich 11 Santa Fe, NM

12 for Plaintiffs-Appellees

13 R. Alfred Walker, Legal Counsel 14 Richard B. Word, Legal Counsel 15 Santa Fe, NM

16 for Defendants-Appellants

17 Greenberg Traurig, LLP 18 Jon T. Neumann 19 Phoenix, AZ

20 for Intervenors-Appellants

21 Rodey, Dickason, Sloan, Akin & Robb, P.A. 22 Charles K. Purcell 23 Albuquerque, NM

24 for Amicus Curiae Presbyterian Healthcare Services 1 OPINION

2 BUSTAMANTE, Judge, retired, sitting by designation.

3 {1} Plaintiffs filed a declaratory judgment action against the Superintendent of

4 Insurance 1 and the Office of the Superintendent of Insurance (collectively, OSI)

5 challenging the process used to allow certain hospitals to attain Qualified Health

6 Provider (QHP) status under the Medical Malpractice Act (MMA), NMSA 1978,

7 §§ 41-5-1 to -29 (1976, as amended through 2021). The district court ruled in favor

8 of Plaintiffs, and OSI appeals. Interestingly, however, OSI does not challenge the

9 substance of the district court’s judgment. Instead, it argues that events subsequent

10 to entry of the judgment have rendered the matter moot. OSI asks us to dismiss the

11 appeal, remand, and vacate the district court’s judgment. OSI also asserts—for the

12 first time—that Plaintiffs did not have standing to bring the action. In addition, OSI

13 argues that the district court abused its discretion when it denied its motion to join

14 the hospitals as necessary parties under Rule 1-019 NMRA.

1 John Franchini was the named defendant as the Superintendent of Insurance in the district court proceedings. However, Franchini’s tenure as Superintendent ended on December 31, 2019, after this appeal was filed. Jennifer A. Catechis was appointed Interim Superintendent, effective January 21, 2023. See NMSA 1978, § 59A-2-2.1(F) (2015, amended 2020) (providing for appointment of Interim Superintendent); see also Denish v. Johnson, 1996-NMSC-005, ¶ 47, 121 N.M. 280, 910 P.2d 914 (noting officials appointed to fill vacancies “will remain in office with all the powers of that office until the successor is duly qualified”). Pursuant to Rule 12-301(C)(1) NMRA, Catechis was “automatically substituted” as Defendant and the proceedings in this matter shall be pursued in her name for the duration of her tenure as Interim Superintendent. 1 {2} We hold that Plaintiffs did have standing and that the district court did not

2 abuse its discretion in initially refusing to join the hospitals. We disagree that the

3 matter is now moot.

4 BACKGROUND

5 {3} Plaintiffs are three long-time practicing physicians in New Mexico. Plaintiffs

6 asserted that they—along with the other doctors in their respective practice groups—

7 have held QHP status and have been insured under the MMA for over twenty years.

8 As such, they have been surcharged by OSI and made yearly contributions to the

9 Patient’s Compensation Fund (the Fund) since they became QHPs. Plaintiffs

10 generally asserted that they depend on the Fund to pay their portion of the

11 professional liability obligations that exceed their mandated private insurance

12 coverage, and that the solvency of the Fund is threatened by the decision of OSI to

13 allow hospitals to qualify as QHPs and share in the benefits of the Fund.

14 {4} Plaintiffs asserted that the Fund experienced an accelerating actuarial deficit

15 in the years prior to the filing of their complaint which resulted in OSI imposing two

16 significant surcharges on physician QHPs. Plaintiffs also alleged that the surcharges

17 imposed on physician QHPs would “dramatically increase” as the Fund “takes

18 responsibility for the risk and liability” of the hospitals and outpatient care facilities

19 illegally granted QHP status by OSI.

2 1 {5} Plaintiffs asserted that OSI acted improperly in three ways when it granted the

2 hospitals and outpatient facilities QHP status. First, they argued that it did not

3 comply with the Administrative Procedures Act (APA), NMSA 1978, §§ 12-8-1 to

4 -25 (1969, as amended through 1999). 2 Specifically, they argued that the APA

5 required OSI to publically propose and adopt rules reflecting how it would carry out

6 its responsibilities under the MMA with regard to assessing the risks posed by

7 hospitals before they were allowed to qualify as QHPs. Second, they asserted that

8 OSI failed to comply with NMSA 1978, Section 59A-2-10 (1984) of the New

9 Mexico Insurance Code in that it did not create and sign an order stating the grounds

10 on which the order is based. See § 59A-2-10(A), (B). Third, Plaintiffs asserted that

11 OSI violated its common law and statutory duties as the trustee of the Fund when it

12 failed to act in compliance with the APA and the Insurance Code.

13 {6} After OSI filed its answer, the parties filed cross-motions asking the district

14 court to decide the matter on the pleadings. The arguments made in the motions

15 mirrored the assertions in the pleadings, with OSI specifically asserting that the APA

16 and the Insurance Code did not apply to its duties under the MMA and that its actions

17 in granting QHP status were merely ministerial. After hearing oral argument on the

18 motions and taking the matter under advisement, the district court reconvened the

OSI was made subject to the APA in 2013. 2013 N.M. Laws, ch. 74, § 13; 2

see NMSA 1978, § 59A-2-8(J) (2013, amended 2021 as § 59A-2-8(A)(10)).

3 1 parties and announced its decision orally. The district court agreed with the

2 Plaintiffs’ legal position, rejecting OSI’s arguments that the APA and the Insurance

3 Code did not apply to its actions under the MMA and that its actions were

4 ministerial. The district court, however, was not convinced that the Plaintiffs’

5 requested remedy—declaring all of OSI’s actions void—was appropriate. Thus, the

6 district court asked for proposed forms of a dispositive order from the parties.

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McAneny v. Catechis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcaneny-v-catechis-nmctapp-2023.