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

• Petitioner submitted an Inspection of Public Records Act (IPRA) request to the New Mexico Livestock Board (NMLB) for records regarding various animals for a specific time period. After receiving some documents, the Petitioner discovered additional documents related to the impoundment of a gray thoroughbred horse in February 2021 through another IPRA request to a district court. The Petitioner contended that the Respondents had improperly withheld responsive public records in violation of the law (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Petitioner: Argued that Respondents improperly withheld responsive public records in violation of the law and failed to completely, adequately, and fully respond to the written request for inspection of public records (para 3).
• Respondents: Defended the district court’s reasoning by arguing that innocent omissions and oversights do not amount to denials of IPRA requests and contended that they had not intentionally or in bad faith withheld any documents (para 11).

Legal Issues

• Whether the district court erred by concluding that Respondent’s response to Petitioner’s IPRA request did not constitute a “denial” for purposes of statutory damages under Section 14-2-11(C), and compensatory damages, attorneys’ fees, and costs under Section 14-2-12(D) (para 7).
• Whether IPRA forecloses awards of damages, attorneys’ fees, and costs based on Petitioner’s choice to seek a writ of mandamus instead of asking Respondent to produce the wrongfully withheld documents (para 13).

Disposition

• The Court of Appeals reversed the district court’s denial of Petitioner’s requests for statutory per diem damages, compensatory damages, attorneys’ fees, and costs, and remanded for reconsideration of those requests (para 15).

Reasons

• The Court of Appeals, with Judges Zachary A. Ives, J. Miles Hanisee, and Jacqueline R. Medina concurring, found that the district court misinterpreted IPRA by concluding that Respondents did not deny Petitioner’s request. The court clarified that an omission may amount to a denial under IPRA if a request is not permitted within fifteen days and is not deemed excessively burdensome or broad, which applied in this case (paras 6-9). The court also found that the district court erred in reasoning that no denial occurred because Respondents produced documents in good faith and that their failure to produce certain documents was a mistake or oversight. The court stated that IPRA does not require documents to be withheld intentionally for a denial to occur (paras 10-11). Furthermore, the court disagreed with the district court’s reasoning that Petitioner’s decision to file a petition for a writ of mandanus instead of submitting a new or additional IPRA request to Respondents was a valid reason for denying damages, attorneys’ fees, and costs. The court emphasized that IPRA explicitly permits enforcement through litigation without the need for administrative exhaustion (paras 12-14).