Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
Citizens State Bank v. Christmas
Citations: 107 N.M. 220; 755 P.2d 64Docket: No. 17365
Court: New Mexico Supreme Court; May 31, 1988; New Mexico; State Supreme Court
Defendant-appellant Christmas challenges a district court ruling that awarded him $5,658 based on an agistor’s lien for cattle grazing on his land. Christmas had a grazing agreement with Shane Hasha, stipulating a minimum delivery of 2,200 cattle by May 10, 1986, and a payment structure based on the animals' weight gain, along with penalties for late or non-delivery. Hasha delivered only 205 cattle, leading Christmas to file an agistor’s lien on August 8, 1986, after Hasha defaulted on the delivery. Hasha had previously secured loans from Citizens State Bank with a lien on his cattle, which the Bank perfected after Christmas filed his lien. After selling the surviving cattle, the Bank sought to determine lien priorities, claiming Christmas's lien only covered the feed for the cattle actually delivered, while Christmas argued it should also include penalties for the undelivered cattle. The trial court ruled in favor of Christmas for the amount corresponding to the actual weight gain of the delivered cattle but did not allow recovery for penalties related to the breach of contract. The court limited Christmas's lien to $5,658, reasoning that the agistor's lien does not extend to damages for breach of contract. Christmas's appeal focuses on whether New Mexico law grants an agistor a lien not only for feed and care but also for damages from the lessee's breach of contract. The appellate court affirmed the lower court's decision. Section 48-3-7 establishes that lessees and agistors who provide feed or pasture have a lien on the property and livestock of those they serve until payment is made. If a cattle owner fails to pay under a grazing agreement, the agistor can impose a lien on the cattle for payment security. The defendant contended that the district court incorrectly interpreted the grazing agreement's rental provisions, labeling late or deficient cattle delivery as an unenforceable penalty. The defendant proposed a weight gain formula for calculating rentals due based on timely and late deliveries. However, the court determined that the cattle did not gain the anticipated weight, rendering the defendant's rental calculations unenforceable. Furthermore, the agistor's lien statute does not cover breaches related to late or nondelivery; it only secures payment for feed, care, and pasturage provided for cattle actually delivered. A cited analogous case reinforced this interpretation, concluding that a lien cannot extend to future rentals or damages resulting from contract breaches. The court affirmed that the lien applies solely to the care and maintenance of delivered cattle and noted that the defendant had already pursued remedies for breach of contract. Additionally, the defendant failed to preserve an argument that the grazing agreement was a security agreement under the UCC, as he did not request findings of fact or conclusions of law on this matter. Consequently, the trial court's judgment was upheld.