N.M. Law Grp., P.C. v. Byers, 413 P.3d 875

Plaintiff New Mexico Law Group sued Paul Byers for unpaid legal fees, asserting an outstanding balance of $19,078.60 for services including criminal representation.
The district court granted plaintiff’s motion for summary judgment based on undisputed facts that Byers agreed to pay and had not fully paid.
Byers moved to vacate the summary judgment, arguing his constitutional right to a jury trial had been violated.
The district court denied Byers’s motion to vacate.
Byers appealed the denial; the Court of Appeals issued a calendar notice proposing to affirm and Byers filed a memorandum in opposition.
The Court of Appeals considered whether the motion-to-vacate denial was an abuse of discretion and reviewed whether summary judgment infringed Byers’s jury-trial rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in denying the motion to vacate summary judgment	Plaintiff argued the summary judgment was proper because there were no genuine disputes of material fact (agreement to pay, services rendered, unpaid balance).	Byers argued the summary judgment violated his constitutional right to a jury trial; jury must decide disputed facts.	Denial affirmed: no abuse of discretion because no material factual disputes existed and no jury right was violated.

Fid. & Deposit Co. of Maryland v. United States, 187 U.S. 315 (establishing that summary judgment procedures prescribe means of making an issue and do not inherently violate the jury right)
Evans Fin. Corp. v. Strasser, 99 N.M. 788 (1983) (no jury right for purely equitable claims)
Blea v. Fields, 120 P.3d 430 (2005) (if disputed facts are material to legal claims, those facts must be preserved for jury trial)
Rekart v. Safeway Stores, Inc., 468 P.2d 892 (1970) (summary judgment improper where any issue as to a material fact exists)
James v. Brumlop, 609 P.2d 1247 (1980) (appeal from denial of motion to reopen cannot review the original judgment’s propriety)