Snow v. Warren Power & Mach., Inc.

Summary

The New Mexico Supreme Court held that when a plaintiff files a motion for leave to amend a complaint before the statute of limitations expires, and the motion includes the proposed amended pleading, the filing of the motion is deemed the filing date of the amended complaint for statute‑of‑limitations purposes, so the later filing of the amended complaint is not time‑barred. The Court reversed the Court of Appeals and adopted this “deeming” rule.