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

• James Scott Boyd, individually and as personal representative or receiver and heir to the Estate of Nathan Boyd, filed a Form B Notice of Intent to Participate in a stream system issue regarding surface water rights in the Lower Rio Grande stream system. This action was part of a general adjudication of water rights in the Lower Rio Grande Basin. Boyd's claims were previously dismissed in a 2012 expedited inter se proceeding, where the district court found his asserted rights were based on existing works he does not own and over which he has not exercised control for over a century. Boyd's claims were also barred by res judicata based on earlier judicial decisions related to RGD&IC, Ltd. Despite this, Boyd filed a Form B notice in 2016, asserting legal rights individually and as a successor to Nathan Boyd’s interests.

Procedural History

• Boyd Estate ex rel. Boyd v. United States, 2015-NMCA-018, 344 P.3d 1013, cert. denied, 2015-NMCERT____ (No. 35,026, Jan. 14, 2015): The New Mexico Court of Appeals affirmed the district court's 2012 Order dismissing Boyd's claims to water rights in the Lower Rio Grande Adjudication, finding the claims barred by res judicata.

Parties' Submissions

• Appellant (James Scott Boyd): Argued that his Form B notice should not have been struck because the district court's 2012 Order, which barred his claims by res judicata, contained numerous errors. Boyd sought revision of earlier decisions to consider his well-pleaded facts, including those facts controverting res judicata.
• Appellee (State of New Mexico ex rel. Office of the State Engineer): Argued that Boyd had no legal right to participate in the stream system issue (SS-107) because his individual claims and claims as the personal representative of the Estate of Nathan Boyd had been previously litigated and dismissed.

Legal Issues

• Whether the district court erred by striking Boyd's Form B notice based on the doctrine of res judicata.
• Whether the State Engineer lacks authority to regulate a water right prior to the completion of an adjudication.

Disposition

• The district court's decision to strike Boyd's Form B notice was affirmed.

Reasons

• The Court of Appeals, per Judge Kristina Bogardus, with Judges Megan P. Duffy and Jane B. Yohalem concurring, found that Boyd's claims were barred by res judicata because they had been previously determined in the 2012 Order, which was affirmed by the Court of Appeals and where certiorari was denied by the Supreme Court (paras 6-11). The court explained that res judicata aims to prevent multiple lawsuits on the same claim, promoting efficiency and finality in the judicial process (para 8). Boyd's arguments did not address any errors in the district court’s order from which he appealed but instead focused on relitigating issues related to the 2012 Order and other proceedings (para 6). The court also noted that Boyd failed to preserve the issue of the State Engineer's authority to regulate water rights prior to final adjudication for appeal, as he did not raise this argument in the district court (para 12).