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

• A private prison medical services provider, Corizon Health, contracted with the New Mexico Corrections Department (NMCD) to provide healthcare services in New Mexico correctional and detention centers from 2007 to 2016. Following the termination of their contract, several inmates filed civil claims against Corizon Health alleging improper care and/or sexual assault. Corizon Health settled at least fifty-nine such claims. The Santa Fe New Mexican, Albuquerque Journal, and New Mexico Foundation for Open Government (Petitioners) submitted requests under the Inspection of Public Records Act (IPRA) to inspect and copy all settlement documents involving Corizon Health in its role as a medical services contractor for NMCD. Corizon Health initially agreed to produce the settlement agreements with redactions but later refused, citing confidentiality agreements and arguing that IPRA does not compel the production of this information (paras 2-4).

Procedural History

• District Court of Santa Fe County, July 18, 2016: The district court preliminarily issued an alternative writ of mandamus, ordering Corizon Health to produce the requested settlement agreements or show cause why the writ should not be made permanent. The court later issued a final order granting the writ of mandamus, finding that Corizon Health was performing a public function and acting on behalf of NMCD, thereby subjecting it to IPRA (paras 5, 8).

Parties' Submissions

• Petitioners: Argued that Corizon Health, by providing medical services under contract with NMCD, was performing a public function and thus was subject to IPRA. They contended that the settlement agreements were public records related to the public function performed by Corizon Health and should be disclosed under IPRA (paras 6-7).
• Respondent (Corizon Health): Argued that the settlement agreements were private contracts between Corizon Health and private persons, requiring confidentiality as per the agreements' clauses. They contended that these agreements were not a component of the public function contracted to perform for the state and thus not subject to IPRA (para 5).

Legal Issues

• Whether settlement agreements entered into by Corizon Health, arising from its performance of public functions under contract with NMCD, are public documents subject to disclosure under IPRA (para 17).
• Whether there was sufficient evidence to support the issuance of the writ of mandamus requiring Corizon Health to produce the settlement agreements under IPRA (para 22).
• Whether the use of mandamus was proper to require Corizon Health to produce public records pursuant to IPRA requests (para 24).
• Whether the district court abused its discretion in awarding attorney fees to Petitioners (para 27).

Disposition

• The Court of Appeals affirmed the district court’s orders granting the writ of mandanus and awarding attorney fees to Petitioners (para 30).

Reasons

• Per HANISEE, J. (LINDA M. VANZI, J., and RICHARD C. BOSSON, J. Pro Tempore, concurring):
  The court held that the settlement agreements were public records under IPRA because they were created and maintained in relation to public business, specifically the medical care and personal safety of inmates held by NMCD. The court emphasized IPRA's purpose of providing the public with the greatest possible information regarding the affairs of government (paras 16-21).
  The court found sufficient evidence in the record to support the issuance of the writ, noting that Corizon Health itself had listed the settlements in response to Petitioners' IPRA requests and admitted to providing medical services under contract with NMCD (para 22).
  The court determined that the use of mandamus was proper in this case, as IPRA itself allows for mandamus to enforce its provisions. The court rejected Corizon Health's argument that mandamus was an inappropriate remedy due to the novel and complex nature of the case (paras 24-26).
  The court concluded that the district court did not abuse its discretion in awarding attorney fees to Petitioners. It found that the district court's award was supported by substantial evidence and that the court properly concluded that contingency fees were not a part of the attorney fee award (paras 27-29).