N.M. Stat. § 45-3-1006
Limitations on actions and proceedings against
distributees.
Unless previously adjudicated in a formal testacy proceeding or in a proceeding
settling the accounts of a personal representative or unless otherwise barred, the claim
of a claimant to recover from a distributee who is liable to pay the claim and the right of
an heir or devisee or of a successor personal representative acting in their behalf to
recover property improperly distributed or its value from any distributee is forever barred
at the later of three years after the decedent's death or one year after the time of its
distribution, but all claims of creditors of the decedent are barred one year after the
decedent's death. This section does not bar an action to recover property or value
received as the result of fraud.