AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• An attorney, representing three employees of the Attorney General’s Office in a federal court employment dispute, requested employment records from the Attorney General’s Office under the Inspection of Public Records Act (IPRA) while a discovery stay was in effect due to an Eleventh Amendment immunity defense. The Attorney General denied the request, suggesting it was an attempt to circumvent the discovery process. The attorney then filed a lawsuit in state district court to enforce his IPRA request (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellee: Argued that the discovery stay did not preempt statutory rights under IPRA and that the Attorney General violated IPRA by denying the request for records. Sought damages under IPRA for the wrongful withholding of documents (paras 2-3, 9).
• Defendant-Appellant: Contended that per-day damages were incorrectly awarded under the section of IPRA governing failures to respond rather than wrongful denials. Argued that once a request was denied, it ceased to exist, and therefore, daily damages should not continue to accrue after the denial (para 5).

Legal Issues

• Whether damages of $100 per day were correctly and reasonably awarded in response to the wrongful withholding of documents by the New Mexico Attorney General in violation of IPRA (para 1).
• Whether the district court erred in awarding damages without stating the nature and purpose of the damage award and without further support by findings (para 1).

Disposition

• The Court of Appeals reversed the district court's award of damages, finding it unsupported by findings supporting compensatory damages, which are a prerequisite to punitive damages as were awarded in this case (para 20).

Reasons

• Per RODERICK T. KENNEDY, Chief Judge, with concurrence from LINDA M. VANZI, Judge, and J. MILES HANISEE, Judge:
  The court concluded that the district court erred in awarding damages under NMSA 1978, Section 14-2-12(D) without stating the nature and purpose of the damage award and without further support by findings (para 1).
  It was determined that per-day damages are permitted under Section 14-2-12 of IPRA, which covers actions to enforce a request that was denied, and mandates the court to award damages without further restrictions on their nature (paras 6-7).
  The court disagreed with the Attorney General's argument that statutory damages are solely intended to be compensatory, noting that Section 14-2-12 does not limit the nature of damages that may be awarded (para 10).
  The court found that the district court's method of calculating damages, differentiating between the time during which the federal stay was in effect and the time after it was lifted, was reasonable but required further findings to support any award of compensatory damages (paras 9-10, 17).
  The court disagreed with the Attorney General's argument that a denied request terminates for purposes of calculating damages, affirming that damages can accrue from the wrongful denial to the day the records were produced (para 18).
  The decision was reversed for further proceedings in accordance with the ruling, emphasizing the need for the district court to enter findings supporting any award of compensatory damages (para 20).