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

• John Stinebaugh, a horse trainer, was involved in a case concerning the horse "Dooley Dash," which he trained and which won a race at Sunland Park on February 25, 2011. Following the race, a blood sample from the horse tested positive for Clenbuterol, a regulated drug, in prohibited quantities. The initial and a subsequent independent test confirmed the presence of the drug, leading to a violation of the Racing Commission Rules (paras 2-3).

Procedural History

• Ruidoso Downs Board of Stewards, July 2, 2011: Determined a violation of Racing Commission Rules based on drug test results, imposing a seven-day license suspension, a $500 fine, and a loss of purse on Stinebaugh (para 3).
• New Mexico Racing Commission, September 30, 2011: Appointed a hearing officer who presided over a hearing and issued findings on December 30, 2011. The Commission adopted these findings, amending the Board's ruling and issued its decision on February 2, 2012 (para 4).
• District Court of Bernalillo County, March 26, 2013: Affirmed the Commission’s decision upon Stinebaugh's petition for writ of certiorari (para 4).

Parties' Submissions

• Petitioner-Appellant (Stinebaugh): Argued that the Commission failed to follow its own regulations regarding the timely issuance of the hearing officer’s decision and did not comply with the Open Meetings Act (para 1).
• Respondent-Appellee (New Mexico Racing Commission): Asserted that the hearing officer’s report's delay did not prejudice Stinebaugh and that the Commission properly exercised its authority when disciplining Stinebaugh (paras 7, 11).

Legal Issues

• Whether the New Mexico Racing Commission's failure to follow its own regulations regarding the timely issuance of the hearing officer’s decision affected the validity of its decision against Stinebaugh (para 1).
• Whether the Commission complied with the Open Meetings Act (para 1).

Disposition

• The Court of Appeals reversed the Commission's decision and remanded for dismissal of the charges against Stinebaugh (para 16).

Reasons

• The Court, per Judge Roderick T. Kennedy with Judges Timothy L. Garcia and M. Monica Zamora concurring, found that the Commission did not act in accordance with its own regulations, specifically failing to issue the hearing officer’s decision within the time limitations specified in the administrative code. This failure was deemed significant enough to void the Commission's decision, as New Mexico case law establishes that an agency’s failure to comply with its own regulations in rendering a decision is a basis for voiding that decision. The Court determined that the untimely decision was contrary to the Commission’s regulations and thus not "in accordance with law." The Court also noted that to allow agencies to arbitrarily delay their proceedings would be contrary to the requirements in the regulations for prompt disposition of license suspension proceedings. Since the issue of the Commission’s failure to follow regulations was dispositive, the Court did not address the Open Meetings Act issue (paras 7-15).