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

• Diego Olivas was stopped and cited for a traffic violation while driving his 2006 Jeep in Santa Fe on February 25, 2010. At the time, his license was revoked due to a DWI conviction from May 22, 2008, with eligibility for reinstatement on March 8, 2009, pending a reinstatement fee which Olivas had not paid. Consequently, his vehicle was impounded under the City's vehicle forfeiture ordinance for being operated by someone with a revoked license due to a prior DWI conviction (paras 2-4).

Procedural History

• District Court of Santa Fe County, Barbara J. Vigil, District Judge: Dismissed the City’s petition for forfeiture and ordered the return of the vehicle to Olivas, concluding that the City’s vehicle forfeiture ordinance did not apply to Olivas’s conduct because his license was revoked merely for failing to pay a reinstatement fee, which the court deemed a pro forma requirement (para 5).

Parties' Submissions

• City of Santa Fe: Argued that the vehicle was subject to forfeiture under the ordinance because Olivas's driving privileges remained revoked until he met all requirements for reinstatement, which he failed to do by not paying the reinstatement fee (para 8).
• Diego Olivas: Asserted that the failure to pay a reinstatement fee was a minor procedural issue and did not justify the forfeiture of his vehicle. The district court agreed with this position, leading to the dismissal of the City's petition for forfeiture (para 5).

Legal Issues

• Whether a vehicle operated by a person whose license has been revoked due to a DWI conviction but was eligible for reinstatement prior to a traffic stop, yet not reinstated due to non-payment of a fee, is subject to forfeiture under the City's ordinance (para 1).

Disposition

• The Court of Appeals reversed the decision of the district court, holding that the City's vehicle forfeiture ordinance applies to vehicles operated by individuals whose licenses are revoked due to DWI convictions and have not met all requirements for reinstatement, including payment of the reinstatement fee (para 16).

Reasons

• Per LINDA M. VANZI, J. (JONATHAN B. SUTIN, J., RODERICK T. KENNEDY, J., concurring): The appellate court conducted a de novo review and interpreted the City's ordinance and relevant statutes to conclude that a driver's license remains revoked until all requirements for reinstatement are met, including payment of the reinstatement fee. The court found that the ordinance's intent was to protect public health and safety by deterring individuals with revoked licenses due to DWI convictions from driving. It determined that the district court erred in its interpretation that the ordinance did not apply to Olivas's conduct and in ordering the return of the vehicle to him. The appellate court emphasized the clear and unambiguous language of the statute and ordinance, which did not provide exceptions for drivers eligible for reinstatement who had yet to complete the process (paras 7-15).