Whether Section 47-8-36(A)(4) permitted Owner to direct the Village to shut off Resident's water services involves statutory construction and the application of the statute to undisputed facts, which is a question of law that we review de novo. SeeHedicke v. Gunville , 2003-NMCA-032, ¶ 24, 133 N.M. 335, 62 P.3d 1217 (stating that statutory interpretation is an issue of law which this Court reviews de novo); Giant Cab, Inc. v. CT Towing, Inc. , 2019-NMCA-072, ¶ 6, 453 P.3d 466 ("We review de novo the district court's application of law to the facts."). Resident argues the district court misinterpreted two provisions of Section 47-8-36(A)(4) : (1) the meaning of "court order" and (2) language addressing an owner's obligations regarding a resident's unpaid utility charges.
{29} While a trial court has broad discretion when awarding attorney fees, that discretion is limited by any applicable contract provision. Hedicke v. Gunville, 2003-NMCA-032, ¶ 23, 133 N.M. 335, 62 P.3d 1217. Consequently, this Court looks to the contract language to determine the parties' intentions.
{21} A trial court's determination concerning an award of attorney fees is reviewed only for abuse of discretion. Hedicke v. Gunville, 2003-NMCA-032, ¶ 23, 133 N.M. 335, 62 P.3d 1217. When a contract provides that the prevailing party in the litigation shall be awarded reasonable attorney fees and costs, a trial court may abuse its discretion if it fails to award attorney fees.
The Court of Appeals of New Mexico has interpreted "prevailing party" in UORRA's fee-shifting provision, N.M. Stat. Ann. § 47–8–48(A), as " ‘[t]he party to a suit who successfully prosecutes the action or successfully defends against it, prevailing on the main issue, even though not necessarily to the extent of his original contention.’ " Hedicke v. Gunville , 2003-NMCA-032, ¶ 26, 133 N.M. 335, 62 P.3d 1217, 1224 (alteration original)(quoting Black's Law Dictionary 1188 (6th ed. 1990)). The Hedicke v. Gunville court added that "[t]his definition suggests ... that at the end of the entire action, the prevailing party is the party who wins on the merits or on the main issue of the case."
"The trial court may abuse its discretion if it does not award attorney fees contrary to a contractual provision entitling the prevailing party to reasonable attorney fees." See Hedicke v. Gunville, 62 P.3d 1217, 1224 (N.M. Ct. App. 2002). Thus, the prevailing party is entitled to reasonable attorneys' fees and costs under the 2003 Agreement.
It has also been defined as "'the party to a suit who successfully prosecutes the action or successfully defends against it, prevailing on the main issue, even thought not necessarily to the extent of his original contention.'" Mayeux, 131 P.3d at 96 (quoting Hedicke v. Gunville, 133 N.M. 335, 62 P.3d 1217 (N.M.App. 2002)). The assessment "need not be mechanic or formulaic, but is governed by, and should be apportioned according to, the facts and circumstances of the case and the extent to which the parties, in fact prevailed."
See Rule 1-050(A) NMRA. "Therefore, a directed verdict is appropriate only when there are no issues of fact to be presented to a jury." Hedicke v. Gunville , 2003-NMCA-032, ¶ 9, 133 N.M. 335, 62 P.3d 1217. "Any conflicts in the evidence or reasonable interpretations of the evidence are viewed in favor of the party resisting the directed verdict."
{16} “A directed verdict may be granted if there is no legally sufficient evidentiary basis for a reasonable jury to find in favor of a party or may be granted as a matter of law against a party with respect to a claim that cannot, under controlling law, be maintained without a favorable ruling on the issue.” Hedicke v. Gunville, 2003–NMCA–032, ¶ 9, 133 N.M. 335, 62 P.3d 1217. “Directed verdicts are not favored and should only be granted when the jury cannot reasonably and logically reach any other conclusion.”
When we review a district court's ruling on a motion for directed verdict, "any conflicts in the evidence or reasonable interpretations of it are viewed in favor of the party resisting the directed verdict." Hedicke v. Gunville, 2003-NMCA-032, ¶ 9, 133 N.M. 335, 62 P.3d 1217. "The sufficiency of evidence presented to support a legal claim or defense is a question of law for the trial court to decide.
We have also defined the prevailing party as "[t]he party to a suit who successfully prosecutes the action or successfully defends against it, prevailing on the main issue, even though not necessarily to the extent of his original contention." Hedicke v. Gunville, 2003-NMCA-032, ¶ 26, 133 N.M. 335, 62 P.3d 1217 (internal quotation marks and citation omitted). Finally, we have reiterated that the prevailing party is the party that wins on the "main issue of the case."