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

• Santa Fe Pacific Trust (SFPT) owned property in downtown Albuquerque, targeted by two mayors for a potential events arena. Due to publicity and steps taken by the City of Albuquerque (the City) towards this project, SFPT claimed it lost potential sales and leases, leading to a lawsuit against the City for inverse condemnation and deprivation of due process among other claims (paras 1-3).

Procedural History

• District Court of Bernalillo County: Summary judgment entered in favor of the City on SFPT's claims for inverse condemnation and deprivation of due process (para 2).

Parties' Submissions

• Plaintiff-Appellant (SFPT): Argued that the City's pre-condemnation planning and publicity constituted an unconstitutional taking under federal and state laws, and deprived SFPT of due process by damaging its interest in the property (paras 17-18).
• Defendant-Appellee (City of Albuquerque): Contended that its activities amounted to mere planning and publicity surrounding the proposed arena project, which do not constitute a "taking" under either New Mexico or federal condemnation law (para 17).

Legal Issues

• Whether the City's pre-condemnation planning and publicity constituted an unconstitutional "taking" under federal and state laws regarding inverse condemnation (para 2).
• Whether SFPT was deprived of due process by the City's actions (para 2).

Disposition

• The Court of Appeals affirmed the summary judgment in favor of the City on SFPT's claims for inverse condemnation and deprivation of due process (para 2).

Reasons

• Per Cynthia A. Fry, J. (Michael E. Vigil, J., and J. Miles Hanisee, J., concurring):
  Inverse Condemnation under Federal Law: The court held that SFPT failed to demonstrate entitlement to an inverse condemnation claim under federal law, citing that mere fluctuations in value during governmental decision-making are not considered takings in the constitutional sense (paras 21-24).
  Inverse Condemnation under State Law: Adopting a two-part inquiry from Joseph M. Jackovich Revocable Trust v. State Department of Transportation, the court concluded that while SFPT established the City's intention to condemn, it failed to show substantial interference with the use and enjoyment of the property, thus not constituting a taking under state law (paras 25-41).
  Due Process: The court concluded that SFPT's due process claim fails as there was no government regulation impacting the property owner’s use, and the City's planning and publicity did not rise to the level of a regulatory action (para 43).
  Exchange Agreement: The court found that the facts of the Exchange Agreement were not sufficiently tied to the Property claims to defeat the City's motion for summary judgment, indicating that SFPT failed to demonstrate how the alleged breach of the Exchange Agreement resulted in injury to the Property (paras 44-49).
  Disputed Issues of Fact and Preliminary Issues: The court addressed SFPT's arguments regarding disputed issues of fact and preliminary issues, concluding that SFPT's arguments did not preclude summary judgment in favor of the City (paras 50-57).