Pena v. State

CourtNew Mexico Court of Appeals
DecidedDecember 18, 2025
StatusUnpublished

This text of Pena v. State (Pena v. State) 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
Pena v. State, (N.M. Ct. App. 2025).

Opinion

This decision of the New Mexico Court of Appeals was not selected for publication in the New Mexico Appellate Reports. Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions. Electronic decisions may contain computer- generated errors or other deviations from the official version filed by the Court of Appeals.

IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

No. A-1-CA-39744

DAVID P. PENA,

Worker-Appellant,

v.

STATE OF NEW MEXICO and RISK MANAGEMENT DIVISION,

Employer/Self-Insured-Appellees.

APPEAL FROM THE WORKERS’ COMPENSATION ADMINISTRATION Shanon S. Riley Workers’ Compensation Judge

Gerald A. Hanrahan Albuquerque, NM

for Appellant

Paul L. Civerolo LLC Evie M. Jilek Albuquerque, NM

for Appellees

Michael J. Holt, General Counsel Sandra Gardner, Assistant General Counsel Albuquerque, NM

for Amicus Curiae New Mexico Workers’ Compensation Administration

MEMORANDUM OPINION

ATTREP, Judge. {1} This matter is before this Court on remand from certification to the New Mexico Supreme Court. Worker David P. Pena appeals a Workers’ Compensation Administration (WCA) order (1) awarding him the maximum amount of attorney fees allowed under the fee cap (the Cap) in NMSA 1978, Section 52-1-54(I) (2013, amended 2025)1 for the work his attorney performed before the WCA, and (2) denying his request that his employer, the State of New Mexico (Employer), pay 100 percent of his attorney fees, pursuant to Section 52-1-54(F)(4). We affirm.

BACKGROUND

{2} Worker suffered two distinct injuries during the course of his employment as a juvenile correctional officer. The first injury occurred on September 12, 2012, when Worker tripped while walking up some concrete steps. The second injury occurred on November 29, 2012, when Worker was restraining a large juvenile. Notwithstanding his injuries, Worker continued working for Employer without any wage loss until March 7, 2013.

{3} Worker filed a complaint for workers’ compensation benefits on May 2, 2013. Following a mediation conference held on June 11, 2013, a mediator entered a recommended resolution, which Employer rejected. Pursuant to Section 52-1-54(F), Worker then sent Employer an offer of judgment on August 2, 2013. As relevant here, the offer provided that Worker was entitled to temporary total disability (TTD) benefits from September 12, 2012, through maximum medical improvement (MMI), less $10. Employer did not accept the offer. Worker and Employer eventually reached a settlement and agreed to entry of a compensation order (Compensation Order) on October 21, 2020. In pertinent part, the Compensation Order provided that Worker reached MMI on August 15, 2018, and was entitled to TTD benefits from March 7, 2013, through August 15, 2018.

{4} On December 2, 2021, Worker applied for an award of attorney fees and costs for the work his counsel performed before the WCA. Worker acknowledged that his attorney’s fees were capped by Section 52-1-54(I) to the amount of $22,500 per injury, but asserted to the workers’ compensation judge (WCJ) that the Cap was unconstitutional. He thus requested that the WCJ award him $122,600 in attorney fees or, in the alternative, the maximum amount of $45,000 allowed by Section 52-1-54(I). Additionally, Worker contended that, pursuant to Section 52-1-54(F)(4), Employer should be required to pay 100 percent of Worker’s attorney fees—rather than 50 percent—because his offer of judgment sought benefits in an amount less than he ultimately obtained. In the order awarding fees and costs, the WCJ did not address Worker’s contention that the Cap was unconstitutional. See, e.g., Rodriguez v. Brand W. Dairy, 2015-NMCA-097, ¶ 4, 356 P.3d 546 (“WCJs do not have authority to rule on the constitutionality of statutes.”). As for Worker’s contention that Employer should pay 100 percent of fees, the WCJ simply ruled: “Worker’s claim to fee shifting pursuant to

1All citations in this opinion to Section 52-1-54 are to the 2013 version of that statute because it was the version in effect at the time Worker was awarded his attorney fees and extended his offer of judgment. Section 52-1-54(F)(4) is not well-taken and shall be denied. Worker’s award of attorney fees shall be payable 50% by Worker and 50% by Employer.” Worker appeals.

DISCUSSION

I. Section 52-1-54(I)’s Fee Cap

{5} The attorney fee cap provision at issue in this case provides:

Attorney fees, including, but not limited to, the costs of paralegal services, legal clerk services and any other related legal services costs on behalf of a claimant or an employer for a single accidental injury claim, including representation before the workers’ compensation administration and the courts on appeal, shall not exceed twenty-two thousand five hundred dollars ($22,500).

Section 52-1-54(I). Worker argues on appeal that the Cap is unconstitutional on the ground it violates the separation-of-powers doctrine found in Article III, Section 1 of the New Mexico Constitution. Because this argument required the resolution of questions involving our Supreme Court’s inherent and constitutional authority to regulate the practice of law, see, e.g., State ex rel. Norvell v. Credit Bureau of Albuquerque, Inc., 1973-NMSC-087, ¶ 26, 85 N.M. 521, 514 P.2d 40 (“[T]he regulation of the practice of law is the exclusive constitutional prerogative of th[e Supreme Court].”), we certified this matter (and another raising the same issue) to the Supreme Court. See Order of Certification to the New Mexico Supreme Court, Pena v. State, A-1-CA-39744, Trujillo v. Luna Cmty. Coll., A-1-CA-39842 (N.M. Ct. App. Sept. 6, 2023). On July 3, 2025, the Supreme Court issued its decision in Pena v. State, 2025-NMSC-041, ___P.3d___. As relevant here, Pena held (1) the Supreme “Court’s inherent authority is not infringed by legislative regulation of pleading, practice, and procedure that occurs outside of the Judiciary’s courts,” id. ¶ 38 (emphasis omitted); and (2) “quasi-judicial proceedings such as those within the WCA exist outside the judicial branch,” id. ¶ 35. The Supreme Court thus concluded that, although the “regulation of attorney fees generally falls within the purview of th[e] Court’s inherent powers and power of superintending control, . . . regulation of attorney fees specifically within the workers’ compensation context does not.” Id. ¶ 42. Given this, Worker’s contention that the Cap as applied in his case is unconstitutional is foreclosed.2

{6} Worker separately contends on appeal that an attorney “fee in the range of $90,000.00 to $122,000.00 [for his attorney’s work done before the WCA] would be . . . reasonable [and] well-earned.” As noted, however, our Supreme Court held that the Cap—in this case, $45,000—was constitutional for work done before the WCA. See id. ¶¶ 33-42. Further, the Court rejected the idea that judicial review of attorney fees in a

2The Supreme Court additionally held that Section 52-1-54(I) is unconstitutional inasmuch as it attempts to impose a cap on the recovery of attorney fees for work performed on appeal to New Mexico courts. See Pena, 2025-NMSC-041, ¶¶ 52-59. The issue of whether Worker is entitled to any such attorney fees, however, is not currently before us. quasi-judicial setting, such as the WCA, included the ability to award a fee beyond the Cap. See id. ¶¶ 44-51. In light of these conclusions, Worker’s contention that his attorney should be awarded attorney fees in excess of the Cap is not well taken. We accordingly affirm the WCA order limiting Worker’s recovery of attorney fees to $45,000 for the work his counsel performed before the WCA.

II.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State Ex Rel. Norvell v. Credit Bureau of Albuquerque, Inc.
514 P.2d 40 (New Mexico Supreme Court, 1973)
Baker v. Endeavor Servs., Inc.
428 P.3d 265 (New Mexico Supreme Court, 2018)
Baker v. Endeavor Servs.
2018 NMSC 35 (New Mexico Supreme Court, 2018)
Rodriguez v. Brand West Dairy
2015 NMCA 097 (New Mexico Court of Appeals, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Pena v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pena-v-state-nmctapp-2025.