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

• La Vida Llena, a continuing care facility, sought a property tax exemption under NMSA 1978, Section 7-36-7(B)(1)(d), which exempts facilities that donate or render a portion of their services or facilities for charitable purposes. The facility operates under the New Mexico Continuing Care Act, catering to the elderly with a financial model requiring residents to pay an entrance fee and monthly fees, which remain constant regardless of the level of care needed over time. La Vida Llena applied for a property tax exemption, which was denied by the Assessor, leading to an appeal to the Board. The Board upheld the denial, finding that La Vida Llena did not meet the statutory requirements for the exemption because it did not donate or render gratuitously a portion of its services or facilities for charitable purposes (paras 2-5).

Procedural History

• District Court of Bernalillo County: Reversed the Board's decision, holding that La Vida Llena does donate or render gratuitously a portion of its services or facilities, and that the statute does not specify a minimum amount for such charitable acts (para 6).

Parties' Submissions

• Appellant (Karen Montoya, Bernalillo County Assessor): Argued that the district court erred by determining that the word "portion" in Section 7-36-7(B)(1)(d) does not contain a minimum quantitative threshold for the amount of services and facilities a continuing care facility must donate or render gratuitously to qualify for the exemption. Also contended that the Board's factual finding that La Vida Llena failed to donate a "meaningful" portion of its services or facilities should not have been rejected (paras 7, 17-18).
• Appellee (La Vida Llena): Contended that it meets the criteria for a property tax exemption under Section 7-36-7(B)(1)(d) by donating or rendering gratuitously a portion of its services or facilities for charitable purposes, without a statutory requirement for a minimum threshold amount.

Legal Issues

• Whether La Vida Llena "donates or renders gratuitously a portion of its services or facilities" as required by Section 7-36-7(B)(1)(d) for a property tax exemption, and if so, whether there is a minimum threshold amount that must be met (para 8).

Disposition

• The Court of Appeals affirmed the district court's decision, holding that Section 7-36-7(B)(1)(d) does not require a minimum threshold amount of donated or gratuitously rendered services or facilities for a continuing care facility to receive the property tax exemption (para 22).

Reasons

• The Court, per Judge Wechsler, with Judges Vigil and Garcia concurring, held that the statutory language of Section 7-36-7(B)(1)(d) does not specify a minimum amount for the charitable acts required for a property tax exemption. The Court interpreted "portion" according to its plain meaning, which does not imply a quantitative threshold. The Court also found that the legislative intent was to encourage charitable activities by continuing care facilities without imposing a strict quantitative requirement. The Court rejected the Assessor's argument for a case-by-case determination of what constitutes a "meaningful" portion, emphasizing that such an approach would require rewriting the statute, which is beyond the Court's role. The Court concluded that the district court did not err in its interpretation of the statute or in its treatment of the Board's factual findings (paras 9-22).