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Decision Content

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Facts

  • A group of plaintiffs, including individuals and the estate of Dr. Nathan E. Boyd, appealed from two district court orders related to a water-adjudication case. The case involves claims to water rights and allegations of fraud committed by agents of the United States over 100 years ago, which the plaintiffs argue gave them superior ownership rights to the water claimed by the United States. The appeals were consolidated for consideration by the Court of Appeals of New Mexico.

Procedural History

  • District Court of Doña Ana County, February 17, 2014: Order granting partial summary judgment on certain issues, denying plaintiffs' motion for summary judgment, and setting a scheduling conference.
  • District Court of Doña Ana County, June 18, 2014: Order denying plaintiffs' motion to stay further proceedings.

Parties' Submissions

  • Plaintiffs-Appellants: Argued that they have superior ownership rights to the water claimed by the United States due to alleged fraud by agents of the United States over 100 years ago. They sought summary judgment on their "superior-title" claim and a stay of further proceedings.
  • Defendants-Appellees (United States and Elephant Butte Irrigation District): Filed motions to dismiss each appeal for lack of appellate jurisdiction, arguing that the appeals were not taken from a final, appealable order.

Legal Issues

  • Whether the Court of Appeals has jurisdiction over the appeals based on the finality of the district court's orders.
  • Whether the district court's orders fully and finally disposed of all the plaintiffs' claims, specifically their "superior-title" claim.

Disposition

  • The Court of Appeals dismissed both appeals for lack of jurisdiction, finding that neither appeal was taken from a final, appealable order.

Reasons

  • The Court, consisting of Judges Michael D. Bustamante, Jonathan B. Sutin, and Timothy L. Garcia, concluded that the district court's orders did not dispose of all issues of law and fact in the proceedings, thus not constituting final, appealable orders. The Court noted that the February 17, 2014, order was a grant of partial summary judgment and did not resolve all claims in the adjudication. Similarly, the June 18, 2014, order denying a stay of proceedings did not resolve all legal and factual issues. The Court also found that the district court has not yet made a final decision disposing of all claims raised by the plaintiffs, indicating that further proceedings were contemplated to address unresolved issues, including the "superior-title" claim (paras 3-10).
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