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

• In December 2013, nine plaintiffs filed a lawsuit against the City of Albuquerque, challenging the City’s Motor Vehicle Seizure and Forfeiture Ordinance. They sought to represent a class of persons and businesses affected by the ordinance, alleging violations of various constitutional rights and entitlement to declaratory and injunctive relief. The district court denied their motion for class certification due to concerns about the adequacy of class counsel and the standing of class representatives. Subsequently, the plaintiffs amended their complaint to remove all class claims and informed the court of a pending settlement. Claudeen Crank, aware of the litigation since its early stages, moved to intervene in July 2019 on behalf of herself and the putative class, after the plaintiffs had abandoned their class claims (paras 2-5).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiffs: Argued that the City’s Motor Vehicle Seizure and Forfeiture Ordinance violated the New Mexico Forfeiture Act, the Eighth Amendment (excessive fines), the Fourteenth Amendment (procedural due process), the Fifth Amendment (unlawful taking of property), and constituted an intentional violation of civil and constitutional rights, seeking declaratory and injunctive relief (para 2).
• City of Albuquerque: Argued that Crank’s motion to intervene was untimely, emphasizing her prior knowledge of the lawsuit and the significant delay in seeking intervention (para 8).
• Claudeen Crank (Intervenor-Appellant): Sought to intervene on behalf of a proposed class, arguing that the City’s vehicle forfeiture program violated the Due Process Clause of the United States Constitution by creating an unlawful profit incentive and requiring car owners to prove their innocence (para 5).

Legal Issues

• Whether the district court erred in denying Claudeen Crank’s motion to intervene as untimely (para 6).

Disposition

• The district court’s order denying Claudeen Crank’s motion to intervene was affirmed (para 15).

Reasons

• The Court of Appeals, with Judge Jacqueline R. Medina writing, concurred by Chief Judge J. Miles Hanisee and Judge Gerald E. Baca, held that the district court did not abuse its discretion in denying Crank’s motion to intervene as untimely. The court considered Crank’s prior knowledge of the lawsuit and her delay in seeking to intervene. It was noted that timeliness is a threshold requirement for intervention, and Crank had ample opportunity to intervene earlier in the proceedings. The court also found that permitting Crank’s intervention at a late stage would prejudice the existing parties and cause significant delay. The court distinguished Crank’s reliance on United Airlines, Inc. v. McDonald, noting that Crank’s motion sought to introduce a new class and claims, rather than solely appealing the denial of class certification. The court concluded that the district court’s ruling was not contrary to the logical conclusions demanded by the facts and circumstances of the case (paras 7-14).