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 case involves a dispute over land known as the Tecolote Land Grant. The plaintiffs, representing the Tecolote Land Grant, and certain descendants of Jose Maria Montoya (the Montoya Defendants), are in litigation against third-party Defendants Jill Montoya Marlow, Elizabeth Montoya Garcia, and Andrea Montoya Gurule (the Montoya Sisters), who claim title and a superior interest over the Montoya Defendants to part of the land called the Andrea Tract. Sabrina Montoya Chavez, seeking to intervene as a third-party proposed intervenor-appellant, claims the same interest as the Montoya Sisters, who are her siblings.

Procedural History

• Montoya v. Tecolote Land Grant ex rel. Tecolote Bd. of Trs., 2008-NMCA-014, 143 N.M. 413, 176 P.3d 1145: [Not applicable or not found]
• Tecolote Land Grant ex rel. Tecolote Bd. of Trs. v. Montoya, 2014-NMCA-092, 335 P.3d 222: [Not applicable or not found]
• District Court of San Miguel County: Denied Sabrina Montoya Chavez's motion to intervene in the lawsuit.

Parties' Submissions

• Appellant (Sabrina Montoya Chavez): Argued that the district court erred in denying her motion to intervene in the third-party claim as a matter of right, asserting she has the same interest as the Montoya Sisters, her petition was timely, and she met the requirements for intervention. Additionally, she argued for the first time on appeal that she should be joined as a necessary and indispensable party to the litigation (paras 1, 3, 9).
• Appellees (Montoya Defendants and Montoya Sisters): The Montoya Defendants argued that the litigation did not prevent Chavez from protecting her interest in the Andrea Tract in a separate quiet title claim, implying that Chavez's intervention was unnecessary. The Montoya Sisters' position on Chavez's intervention is not explicitly detailed, but their motion for summary judgment was mentioned in relation to Chavez's claims (paras 7, 11-12).

Legal Issues

• Whether the district court erred in denying Sabrina Montoya Chavez's motion to intervene in the third-party claim as a matter of right.
• Whether Sabrina Montoya Chavez should be joined as a necessary and indispensable party to the litigation.

Disposition

• The Court of Appeals affirmed the district court's denial of Sabrina Montoya Chavez's motion to intervene and held that Chavez is not a necessary party to the litigation.

Reasons

• MEDINA, Judge; DUFFY, Judge; IVES, Judge (concurring): The Court found that the district court did not abuse its discretion in denying Chavez's motion to intervene, as Chavez failed to establish that her ability to protect her interest would be impaired or impeded by the disposition of the action. The Court also determined that Chavez is not a necessary and indispensable party to the litigation, as her ability to protect her interest is not impaired, and her absence does not subject the other parties to a substantial risk of inconsistent obligations. The Court declined to address the timeliness of Chavez's motion to intervene, focusing instead on the merits of her claims for intervention and indispensability under Rules 1-024(A) and 1-019(A) NMRA, respectively (paras 3-13).