Rojas v. Reliable Chevrolet (NM)

CourtNew Mexico Court of Appeals
DecidedOctober 10, 2023
StatusUnpublished

This text of Rojas v. Reliable Chevrolet (NM) (Rojas v. Reliable Chevrolet (NM)) 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
Rojas v. Reliable Chevrolet (NM), (N.M. Ct. App. 2023).

Opinion

The slip opinion is the first version of an opinion released by the Clerk of the Court of Appeals. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Clerk of the Court 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: October 10, 2023

4 No. A-1-CA-39940

5 ISAIAH ROJAS,

6 Plaintiff-Appellant,

7 v.

8 RELIABLE CHEVROLET (NM), LLC 9 d/b/a RELIABLE NISSAN and OLD 10 UNITED CASUALTY COMPANY,

11 Defendants-Appellees.

12 APPEAL FROM THE DISTRICT COURT OF BERNALILLO COUNTY 13 Lisa Chavez Ortega, District Court Judge

14 Bradley Law Firm, LLC 15 Joshua Bradley 16 Albuquerque, NM

17 Treinen Law Office 18 Rob Treinen 19 Albuquerque, NM

20 for Appellant

21 Decker Griffel, LLC 22 Benjamin Decker 23 Lindsay Griffel 24 Albuquerque, NM

25 for Appellees 1 Park & Associates, LLC 2 Alfred A. Park 3 Geoffrey D. White 4 Albuquerque, NM

5 for Amicus Curiae New Mexico Automotive Dealers Association 1 OPINION

2 HANISEE, Judge.

3 {1} Plaintiff Isaiah Rojas appeals the district court’s grant of Reliable Chevrolet

4 (NM), LLC and Old United Casualty Company’s (collectively, Defendants) motion

5 to compel arbitration in his claim for fraud, in violation of the Unfair Practice Act

6 (UPA), NMSA 1978, §§ 57-12-1 to -26 (1967, as amended through 2019);

7 negligence and punitive damages arising from Plaintiff’s purchase of an allegedly

8 defective vehicle; and Defendants’ prior assurances leading to the sale. More

9 specifically, Plaintiff argues that the arbitration agreement provision of the purchase

10 contract should not be enforced because the entire contract is substantively

11 unconscionable due to a provision that bars punitive damages against only the

12 dealership, in this case Reliable Chevrolet. Plaintiff maintains that this bar against

13 punitive damages deprives him of statutorily created treble damages under the UPA

14 and thereby constitutes an unconscionable contract term. The district court ordered

15 arbitration, and we affirm.

16 {2} Whether punitive and treble damages are distinct concepts—such that

17 referencing punitive damages in a contract necessarily implicates treble damages—

18 is a novel question in New Mexico. We hold that in the context of this contract,

19 punitive damages and treble damages are sufficiently distinct such that a bar on the

20 former does not disallow the latter. As such, the arbitration agreement in question is 1 not unconscionable, the contract is enforceable, and the district court was correct to

2 submit the parties’ dispute to arbitration.

3 BACKGROUND

4 {3} In August 2020, Plaintiff purchased a 2018 Chevrolet Sonic from Reliable

5 Chevrolet. Plaintiff alleges that in the process of purchasing the vehicle, the

6 dealership failed to accurately convey the car’s prior damage in order to sell a

7 defective product. In the process of purchasing the vehicle, Plaintiff signed a

8 “Buyer’s Order Agreement and Bill of Sale” provided by the dealership. The entire

9 bill of sale document is three pages: one page for the bill of sale and two additional

10 pages labeled “Additional Terms.” The bill of sale identifies the buyer and vehicle

11 details, but also includes additional information regarding warranties and other legal

12 notices at the bottom in fine print. In particular, the bill of sale states in all capitalized

13 letters (the damages limitation provision):

14 ALL VEHICLES: DEALER IS NOT LIABLE FOR INCIDENTAL, 15 CONSEQUENTIAL OR PUNITIVE DAMAGES ARISING OUT OF 16 THIS SALE OR THE USE OF THIS VEHICLE, INCLUDING BUT 17 NOT LIMITED TO LOSS OF USE, LOSS OF TIME, 18 INCONVENIENCE, TRANSPORTATION, RENTAL, LOSS OF 19 EARNINGS OR PROFITS, OR ANY COMMERCIAL LOSS.

20 Moreover, the “Additional Terms” section includes the following provision in

21 paragraph sixteen (the arbitration provision):

22 Any dispute between Buyer and Dealer arising out of this transaction 23 will be decided by arbitration in the City of Albuquerque, New Mexico 24 under the New Mexico Uniform Arbitration Act and the applicable

2 1 rules of the American Arbitration Association. Any arbitration award 2 may be enforced as provided by law.

3 {4} Following Plaintiff’s filing of his complaint in March 2021, Defendants

4 moved to stay proceedings in district court and compel arbitration under the

5 agreement. Plaintiff opposed the motion, arguing that the arbitration agreement

6 should not be enforced because the contract is unconscionable, primarily based upon

7 the one-sided punitive damages limitation provision. At the motion hearing,

8 Defendants argued that the contract’s bar on punitive damages does not limit

9 statutory damages, such as treble damages under the UPA, and is therefore

10 enforceable. The district court found that “[t]he [b]uyer’s [o]rder contract contains

11 an arbitration agreement. The [c]ourt finds that the arbitration agreement is bilateral,

12 not unconscionable, and should be enforced.”

13 DISCUSSION

14 {5} “[W]hether the parties have agreed to arbitrate presents a question of law, and

15 we review the applicability and construction of a contractual provision requiring

16 arbitration de novo.” Cordova v. World Fin. Corp. of N.M., 2009-NMSC-021, ¶ 11,

17 146 N.M. 256, 208 P.3d 901 (internal quotation marks and citation omitted).

18 “Arbitration agreements are a species of contract subject to generally applicable

19 contract law, including unconscionability.” Peavy ex rel. Peavy v. Skilled Healthcare

20 Grp., Inc., 2020-NMSC-010, ¶ 12, 470 P.3d 218. “A contract is ambiguous if

21 separate sections appear to conflict with one another or when the language is

3 1 reasonably and fairly susceptible of more than one meaning.” Heye v. Am. Golf

2 Corp., 2003-NMCA-138, ¶ 14, 134 N.M. 558, 80 P.3d 495. “We construe

3 ambiguities in a contract against the drafter to protect the rights of the party who did

4 not draft it.” Id. “We consider the documents as a whole to determine how they

5 should be interpreted.” Campbell v. Millennium Ventures, LLC, 2002-NMCA-101,

6 ¶ 15, 132 N.M. 733, 55 P.3d 429.

7 {6} “[U]nconscionability is an affirmative defense to contract enforcement, and

8 under settled principles of New Mexico law, the party asserting an affirmative

9 defense has the burden of proof.” Strausberg v. Laurel Healthcare Providers, LLC,

10 2013-NMSC-032, ¶ 3, 304 P.3d 409. “Unconscionability is an equitable doctrine,

11 rooted in public policy, which allows courts to render unenforceable an agreement

12 that is unreasonably favorable to one party while precluding a meaningful choice of

13 the other party.” Cordova, 2009-NMSC-021, ¶ 21. “A one-sided arbitration

14 agreement is not substantively unconscionable merely by way of its one-sidedness.

15 Rather, our substantive unconscionability law requires a determination that the one-

16 sidedness of an arbitration agreement is unfair and unreasonable.” Peavy, 2020-

17 NMSC-010, ¶ 13.

18 {7} “While there is a greater likelihood of a contract[] being invalidated for

19 unconscionability if there is a combination of both procedural and substantive

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

Related

Cordova v. World Finance Corp. of NM
2009 NMSC 021 (New Mexico Supreme Court, 2009)
Akins v. United Steel Workers of America
2010 NMSC 031 (New Mexico Supreme Court, 2010)
Strausberg v. Laurel Healthcare Providers, LLC
2013 NMSC 032 (New Mexico Supreme Court, 2013)
McLelland v. United Wisconsin Life Insurance
1999 NMCA 055 (New Mexico Court of Appeals, 1999)
Heye v. American Golf Corp., Inc.
2003 NMCA 138 (New Mexico Court of Appeals, 2003)
Fiser v. Dell Computer Corporation
2008 NMSC 046 (New Mexico Supreme Court, 2008)
Berlangieri v. Running Elk Corp.
2003 NMSC 024 (New Mexico Supreme Court, 2003)
Campbell v. Millennium Ventures, LLC
2002 NMCA 101 (New Mexico Court of Appeals, 2002)
Berlangieri v. Running Elk Corp.
2002 NMCA 060 (New Mexico Court of Appeals, 2002)
Hale v. Basin Motor Co.
795 P.2d 1006 (New Mexico Supreme Court, 1990)
Salazar v. Citadel Communications Corp.
2004 NMSC 013 (New Mexico Supreme Court, 2004)
Platz v. Aramburo
17 P.3d 65 (Alaska Supreme Court, 2001)
State ex rel. Balderas v. ITT Educ. Servs., Inc.
421 P.3d 849 (New Mexico Court of Appeals, 2018)
Faulkner v. Territory
6 N.M. 464 (New Mexico Supreme Court, 1892)
Peavy v. Skilled Healthcare Group, Inc.
2020 NMSC 010 (New Mexico Supreme Court, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Rojas v. Reliable Chevrolet (NM), Counsel Stack Legal Research, https://law.counselstack.com/opinion/rojas-v-reliable-chevrolet-nm-nmctapp-2023.