Waterbury v. Nelson

CourtNew Mexico Supreme Court
DecidedJuly 25, 2024
StatusUnpublished

This text of Waterbury v. Nelson (Waterbury v. Nelson) 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
Waterbury v. Nelson, (N.M. 2024).

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: July 25, 2024

4 NO. S-1-SC-40066

5 JASON WATERBURY,

6 Plaintiff-Petitioner,

7 v.

8 GINI NELSON, d/b/a 9 GINI NELSON LAW OFFICE,

10 Defendant-Respondent.

11 ORIGINAL PROCEEDING ON CERTIORARI 12 Francis J. Mathew, District Judge

13 Law Offices of Daymon B. Ely 14 Daymon B. Ely, Esq. 15 Albuquerque, NM

16 for Petitioner

17 Dixon Scholl Carrillo P.A. 18 Briggs F. Cheney 19 Spring V. Schofield 20 Albuquerque, NM

21 for Respondent 1 OPINION

2 BACON, Justice.

3 I. INTRODUCTION

4 {1} On interlocutory appeal to the New Mexico Court of Appeals, the district

5 court certified a single issue of law: “An alleged violation of a Rule of Professional

6 Conduct, specifically [Rule] 16-403 [NMRA], even with expert testimony, cannot

7 create a duty to a non-client for purposes of civil liability.” However, in the present

8 petition for writ of certiorari, Petitioner Jason Waterbury posed a different

9 construction of the issue: whether a New Mexico Rule of Professional Conduct for

10 the legal profession, specifically Rule 16-403, when supported by expert testimony,

11 establishes the standard of care for a lawyer’s obligation to a non-client. This Court

12 granted certiorari on the latter question. Petitioner’s alteration of the issue certified

13 on interlocutory appeal is material—the certified question concerns duty whereas

14 Petitioner’s question concerns breach.1 And because an analysis of duty necessarily

15 precedes the question of breach, to which the standard of care is relevant, we address

1 Throughout the brief in chief, Petitioner frequently modifies the question presented, further complicating analysis of the issues. For example, Petitioner also articulates the question as follows: “May a trial court remove from the jury’s purview, as a matter of law, a legal malpractice/breach of fiduciary duty case where, even though the plaintiff had not retained the attorney, he was reasonably relying on her advice as an unrepresented party and an unintended client?” 1 both. See Herrera v. Quality Pontiac, 2003-NMSC-018, ¶ 6, 134 N.M. 43, 73 P.3d

2 181 (“[A] negligence claim requires the existence of a duty from a defendant to a

3 plaintiff, breach of that duty, which is typically based upon a standard of reasonable

4 care, and the breach being a proximate cause and cause in fact of the plaintiff’s

5 damages.”).

6 {2} In the proceedings below, the district court granted Respondent Gini Nelson’s

7 motion for partial summary judgment, concluding, as a matter of law, “an alleged

8 violation of a Rule of Professional Conduct . . . does not create a duty to a non-client

9 for purposes of civil liability.” Ultimately, Petitioner seeks reversal of the district

10 court’s grant of Respondent’s motion for partial summary judgment, arguing (1)

11 duty is a question for the jury, the analysis of which should be guided by Rule 16-

12 403 and supported by expert testimony and (2) Rule 16-403 2, UJI 13-2411 NMRA,

2 For reference, Rule 16-403 (communications with unrepresented persons) provides: In communicating on behalf of a client with a person who is not represented by counsel, a lawyer shall not state or imply that the lawyer is disinterested. When the lawyer knows or reasonably should know that the unrepresented person misunderstands the lawyer’s role in the matter, the lawyer shall make reasonable efforts to correct the misunderstanding. The lawyer shall not give legal advice to an unrepresented person, other than the advice to secure counsel, if the lawyer knows or reasonably should know that the interests of such a person are or have a reasonable possibility of being in conflict with the interests of the client.

2 1 and Spencer v. Barber, 2013-NMSC-010, 299 P.3d 388, establish both common law

2 duty and the standard of care for a lawyer interacting with a non-client. Petitioner’s

3 position that the Rules of Professional Conduct create a duty is contrary to our

4 caselaw. See Rodriguez v. Del Sol Shopping Ctr. Assocs., 2014-NMSC-014, ¶ 1, 326

5 P.3d 465 (reaffirming that the legal determination of duty is guided by policy).

6 Therefore, we reject Petitioner’s argument that the Rules of Professional Conduct

7 create a duty and affirm the district court’s grant of partial summary judgment.

8 Nonetheless, we take this opportunity to reaffirm the use of the Rules of Professional

9 Conduct to establish standard of care. Finally, because UJI 13-2411 instructs juries

10 to reference the Rules of Professional Conduct to evaluate both duty and breach, we

11 address the inconsistency created by the UJI by clarifying that the rules may guide

12 only the analysis of the standard of care.

13 II. BACKGROUND

14 A. Facts

15 {3} In 2016, Respondent began representing John Emry in his estate planning.

16 Petitioner was Emry’s neighbor and friend, and because of this relationship, Emry

17 requested Petitioner’s assistance in matters related to his estate planning. Therefore,

18 Petitioner contacted Respondent on behalf of Emry, who sought assistance in

19 effectuating gifts and bequests to charities, specified individuals, his daughter and

3 1 only heir, and Petitioner. For this reason, Petitioner regularly communicated with

2 Respondent in his capacity as Emry’s agent. Respondent prepared two powers of

3 attorney on behalf of Emry designating Petitioner as attorney-in-fact for personal

4 and estate planning matters. Emry requested that Petitioner, using his power of

5 attorney, sign documents at Los Alamos National Bank (LANB) relating to the POD

6 account on which Petitioner was named beneficiary. As instructed, Petitioner used

7 the power of attorney to sign POD documents at LANB. Later, Respondent prepared

8 two codicils to Emry’s will. The second codicil designated Petitioner as the payee

9 on death (POD) beneficiary for the LANB account, an account which contained

10 approximately two million dollars. Petitioner then emailed Respondent requesting a

11 document or letter regarding his designation as beneficiary of the LANB account

12 and stating he had signed documents at LANB on behalf of Emry. This email

13 communication is the basis for Petitioner’s malpractice suit. In relevant part the

14 email provides:

15 I also wanted to talk with you about obtaining a 16 document/statement/letter etc. from John regarding the LANB account 17 he recently named me as a beneficiary. John had me sign the documents 18 on his behalf this morning, and each of us want to make sure that no 19 questions are raised in the future regarding this decision. John stated 20 tonight that he feels very strongly about me being the beneficiary on 21 the account and he wants this to be documented correctly if any 22 questions were to be raised.

4 1 {4} It is undisputed Respondent did not respond to Petitioner's email requesting

2 clarification regarding the POD. It is also undisputed that Respondent did not

3 represent Petitioner as his attorney. Upon Emry’s death four years later, LANB

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Related

Spencer v. Paul Barber, Barber & Borg, L.L.C.
2013 NMSC 10 (New Mexico Supreme Court, 2013)
Torres v. State
894 P.2d 386 (New Mexico Supreme Court, 1995)
Leyba v. Whitley
907 P.2d 172 (New Mexico Supreme Court, 1995)
George v. Caton
600 P.2d 822 (New Mexico Court of Appeals, 1979)
Calkins v. Cox Estates
792 P.2d 36 (New Mexico Supreme Court, 1990)
Herrera Ex Rel. Estate of Ruiz v. Quality Pontiac
2003 NMSC 018 (New Mexico Supreme Court, 2003)
Rodriguez v. Del Sol Shopping Ctr. Assoc.
2014 NMSC 14 (New Mexico Supreme Court, 2014)
Oakey v. May Maple Pharmacy, Inc.
2017 NMCA 54 (New Mexico Court of Appeals, 2017)

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Waterbury v. Nelson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/waterbury-v-nelson-nm-2024.