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

• The Superintendent of Insurance for the State of New Mexico, acting as Custodian of the New Mexico Patient’s Compensation Fund (PCF), sought a declaratory judgment to clarify their obligations under the Inspection of Public Records Act (IPRA) in response to an IPRA request from James H. Wood. Wood's request sought materials related to Presbyterian Healthcare Services' application to become a qualified healthcare provider under the Medical Malpractice Act (MMA) and for admission into the PCF. The materials in question included Presbyterian’s application, a list of claims against Presbyterian, Presbyterian’s actuarial reports, and premium amounts paid by Presbyterian for malpractice liability insurance (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Superintendent of Insurance: Argued for clarity on whether they should withhold or disclose the materials requested by Wood, questioning whether the Superintendent, as Custodian of the PCF, is a public body subject to IPRA and if certain provisions allow for the materials to be deemed confidential (para 2).
• James H. Wood: Submitted an IPRA request for materials related to Presbyterian’s application for admission to the PCF, arguing that the requested materials are subject to inspection under IPRA (para 4).
• Presbyterian Healthcare Services: Contended that the requested materials were excepted from disclosure under IPRA, asserting they constituted trade secrets or were protected by attorney-client privilege, or were otherwise excepted from inspection under specific statutory provisions (para 4).

Legal Issues

• Whether the Superintendent, in their role as Custodian of the PCF, is a public body subject to the Inspection of Public Records Act (IPRA).
• Whether the materials requested by James H. Wood are excepted from inspection under IPRA due to confidentiality provisions in the Insurance Code or the Administrative Procedures Act (APA) (para 2).

Disposition

• The Court of Appeals reversed the district court’s decision, which had found the materials requested by Wood were subject to production under IPRA (para 15).

Reasons

• The Court of Appeals, consisting of Judge J. Miles Hanisee, with Judges Katherine A. Wray and Michael D. Bustamante concurring, based its decision on the interpretation of IPRA and the Insurance Code, specifically Section 59A-2-12(B). The court determined that the district court erred in its conclusion that the Superintendent failed to prove the materials requested by Wood were excepted from inspection under IPRA. The appellate court found that the plain language of Section 59A-2-12(B) allows the Superintendent to classify certain information as confidential, thereby exempting it from public inspection under the "as otherwise provided by law" exception in IPRA. The court noted that the district court had misconstrued the requirements of the relevant statutes by expecting explicit promises of confidentiality or specific procedures for deeming information confidential, which are not stipulated in the statute. The appellate court's decision was influenced by the presence of a statement on the application form indicating that materials would be kept confidential, which was deemed sufficient for the purposes of Section 59A-2-12(B). The court also referenced a 2022 administrative regulation, clarifying the confidentiality of information from healthcare providers seeking admission to the PCF, indicating that the controversy in this appeal would not be repeatable under the new regulation (paras 6-14).