The Court of Appeals of New Mexico recently reversed the dismissal of a personal injury case brought by the parents of a child who had been injured in a school-sponsored sports program. The parents alleged that, when their son was 12 years old and a student at a New Mexico middle school, he joined the wrestling team sponsored by the school. He had allegedly never before participated in a school-sponsored sports program before joining the wrestling team. The parents further alleged that on the day of the accident, which was the first day of practice, the boys who were participating were allowed to engage in a game called “king of the mat.” The game’s object was to score take down points and the minor was allegedly taken down on his neck forcefully enough to injure his cervical area by an older, stronger boy with at least one year of wrestling experience.
Following the trial, a jury found in favor of the defendants, a group which included the school district, the principal and athletic director, and the two coaches who were onsite on the day of the accident. On appeal the plaintiffs asserted that the district court had erred in refusing to admit into evidence certain exhibits including excerpts from the school district’s policies and personnel manual and an excerpt from the school district’s athletic handbook.
The Court of Appeals applied an abuse of discretion standard in reviewing the exclusion of evidence. The court explained that an abuse of discretion occurs when a ruling is clearly contrary to the logical conclusions demanded by the facts and circumstances of a case. The court explained further that the party challenging on appeal the exclusion of evidence must show that the erroneous exclusion was prejudicial. The appellate court then reviewed what had occurred at the trial court level with respect to the exhibits at issue.