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

• Arnoldo Carrillo, a racehorse owner and trainer licensed with the New Mexico Racing Commission, experienced the death of one of his horses due to racing activities and three others suffered race-related injuries between September 2012 and April 2013. Following these incidents, four of the five privately owned, licensed racetracks in New Mexico excluded Carrillo from entering their tracks and participating in races held at their facilities. Carrillo filed a lawsuit against the racetracks, their managers, the Board of Stewards for each racetrack, and the Commission, alleging that his rights as a licensee were violated by this exclusion (paras 1-3, 5).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiffs-Appellants: Argued that the racetracks had an unfettered right to exclude patrons but not licensees, and that his exclusion as a licensee violated his rights (para 1).
• Defendants-Appellees (Racetracks): Asserted they had a common law right to exclude both patrons and licensees from their property for any reason other than those specified in the New Mexico Human Rights Act (para 2).

Legal Issues

• Whether racetracks in New Mexico have the common law right to exclude any person, including licensees, for any reason other than those specified in the New Mexico Human Rights Act (para 2).
• Whether the racetracks' actions in excluding Carrillo were arbitrary or had legitimate justification (para 19).

Disposition

• The district court's order granting summary judgment in favor of the racetracks was affirmed, concluding that the racetracks had a common law right to exclude Carrillo and that their actions were not arbitrary but had adequate justification (para 33).

Reasons

• The Court found that New Mexico racetracks possess a common law right to exclude any person, including patrons and licensees, for lawful reasons. This right is affirmed by regulation and statute, and the racetracks' actions in excluding Carrillo were based on legitimate business interests related to safety concerns and the reputation of the racing industry. The Court also noted that Carrillo did not provide sufficient evidence to prove that the racetracks' exclusions were arbitrary. The Court did not decide on the issue of whether the racetracks hold a monopoly over racing in New Mexico but stated that if a monopoly exists, a racetrack must show legitimate justification for excluding a licensee. The Court concluded that the district court correctly applied the common law right in granting summary judgment for the racetracks (paras 2, 12-15, 19-22, 25-33).