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Citations - New Mexico Laws and Court Rules
Chapter 39 - Judgments, Costs, Appeals - cited by 2,986 documents

Decision Content

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Facts

  • Richard Lujan, after being charged in magistrate court, sought to subpoena documents from police agencies and a security firm for an in-camera inspection by Magistrate Judge Alex Naranjo. The State moved for a protective order to quash the subpoenas, which the court granted. Lujan then sought a writ of superintending control, a writ of prohibition, and a stay of magistrate court proceedings in the district court. On the day of the district court hearing, respondents issued a "Notice of In Camera Inspection" granting Lujan the relief he sought, leading to a denial of his petition but a request for costs, which was ultimately denied by the district court.

Procedural History

  • District Court of Santa Fe County: Denied Lujan's petition for writs and his request for costs, stating lack of authority to assess costs against Judge Naranjo or the magistrate court for their judicial actions.

Parties' Submissions

  • Petitioner-Appellant (Lujan): Argued for the issuance of a writ of superintending control, a writ of prohibition, and a stay of magistrate court proceedings. Later sought an award of costs, claiming entitlement as the prevailing party under NMSA 1978, Section 39-3-30 (1966).
  • Respondents-Appellees (State): Filed a motion for a protective order and to quash the subpoenas. Responded to Lujan's petition in district court and agreed to allow in-camera review, which was the relief Lujan initially sought.

Legal Issues

  • Whether the district court erred in denying Lujan's motion for reconsideration of the denial of costs.
  • Whether Lujan was entitled to costs as the prevailing party under NMSA 1978, Section 39-3-30 (1966).

Disposition

  • The Court of Appeals held that the district court did not err in denying Lujan's motion for reconsideration of the denial of costs.

Reasons

  • SUTIN, J., with BUSTAMANTE, J., and VANZI, J., concurring: The court found no abuse of discretion in the district court's denial of costs, considering the peculiar circumstances where the respondents agreed to what Lujan had sought from the magistrate court. The court determined that under these circumstances, it was not appropriate to question the district court's discretion. The court also held that Lujan was not entitled to appeal costs and declined to address Lujan's other points on appeal regarding the authority of district courts to award costs and the applicability of judicial immunity, affirming the district court's decision based on the lack of abuse of discretion.
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