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 State of New Mexico initiated a stream system adjudication concerning the appropriation of water from the Rio Grande River, focusing on whether Respondents’ predecessors had diverted surface water for beneficial use sufficient to establish a priority right prior to 1907. The State offered judgment recognizing certain water rights but declined to recognize a right to divert surface water from the River using a river pump. Respondents objected and, following mediation and referral to a special master, contested the findings regarding pre-1907 surface water rights and subsequent abandonment or forfeiture of any such rights (paras 2-3).

Procedural History

• District Court, June 24, 2013: Referred the subfile proceeding to a special master after mediation failed to reach a settlement (para 2).
• District Court, December 30, 2016: Denied Respondents' motion for reconsideration, adopting the special master's findings that Respondents were entitled to groundwater irrigation and domestic water rights but not to surface water rights (para 4).

Parties' Submissions

• Petitioner-Appellee (State): Argued that Respondents' predecessors in title did not apply water to beneficial use prior to 1907 and that judicial estoppel is not warranted in this case (para 7).
• Respondents-Appellants: Contended that substantial evidence did not support the special master's findings regarding pre-1907 appropriation and abandonment or forfeiture of water rights. They also argued that flood irrigation of pasturelands should be recognized as a beneficial use of water and challenged the district court's denial of their motion for reconsideration (para 1).

Legal Issues

• Whether substantial evidence supported the special master’s findings that Respondents failed to establish a pre-1907 surface water right and that any such right was abandoned or forfeited by 1938 (paras 5-6).
• Whether the special master erred in refusing to recognize flood irrigation of pasturelands as a beneficial use of water (para 3).
• Whether the district court abused its discretion in denying Respondents' motion for reconsideration (para 4).

Disposition

• The Court of Appeals affirmed the district court's order, upholding the special master's findings and the denial of Respondents' motion for reconsideration (para 1).

Reasons

• The Court of Appeals found that Respondents failed to comply with Rule 12-318(A)(3) by not pointing to evidence in the record supportive of the special master’s findings. Despite this, the court reviewed the sufficiency of the evidence and concluded that the district court did not err in adopting the special master’s findings. The court determined that substantial evidence supported the special master's determination that Respondents failed to establish a pre-1907 surface water right and that any such right was abandoned or forfeited by 1938. The court also found that the special master did not err in his treatment of flood irrigation of pasturelands as a beneficial use of water and that the district court did not abuse its discretion in denying Respondents' motion for reconsideration based on newly discovered evidence (paras 5-25).