AI Generated Opinion Summaries

Decision Information

Citations - New Mexico Laws and Court Rules
Rule Set 1 - Rules of Civil Procedure for the District Courts - cited by 4,550 documents

Decision Content

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

  • Aquifer Science, LLC, a Nevada-based company, sought to appropriate water from the Sandia Underground Water Basin for the Campbell Ranch Master Plan Project, a development plan across three counties in New Mexico. The project envisioned residential, commercial, and resort elements, including golf courses. The State Engineer initially denied the application due to a lack of unappropriated groundwater. Following amendments to the application and a change in the State Engineer's position, the district court still denied the application, citing concerns with conservation and significant impairment to existing water rights (paras 3-5).

Procedural History

  • District Court: The application by Aquifer Science, LLC to appropriate water was denied due to concerns with conservation and impairment to existing water rights. Costs were awarded to certain protesting parties, and post-judgment interest was granted on the award of costs.

Parties' Submissions

  • Applicant-Appellant (Aquifer Science, LLC): Argued that the district court's analysis of impairment was incomplete and not supported by substantial evidence, applied an unduly strict interpretation of "conservation of water," and improperly required land-use authorization for the entire project as a condition for approval. Also contended that the cost bill submitted by protesting parties did not comply with requirements, and post-judgment interest cannot be imposed on an award of costs (paras 1, 2).
  • Appellee (State Engineer and Protestants): Supported the district court's findings on impairment and conservation, and argued that the costs and post-judgment interest awarded were justified and in accordance with the law.

Legal Issues

  • Whether the district court's analysis of impairment to existing water rights was complete and supported by substantial evidence.
  • Whether the district court applied an unduly strict interpretation of "conservation of water."
  • Whether the district court improperly required land-use authorization for the entire project as a condition for approval of the water appropriation request.
  • Whether the cost bill submitted by protesting parties complied with the requirements of Rule 1-054(D)(4) NMRA.
  • Whether post-judgment interest can be imposed on an award of costs (paras 1, 2).

Disposition

  • The Court of Appeals affirmed the district court's judgment denying Aquifer Science's request to appropriate water and its order granting costs and post-judgment interest to certain protesting parties (para 2).

Reasons

  • The Court of Appeals found that the district court did not err in its analysis of impairment and conservation, noting that the decision was supported by substantial evidence and that the assessment of conservation is necessarily a case-by-case determination. The court also found no requirement for Aquifer Science to demonstrate land-use authorization as part of its application. Regarding the costs and post-judgment interest, the court determined that the protesting parties' bill of costs was sufficiently detailed and that post-judgment interest on an award of costs is permissible under Section 56-8-4(A). The court's analysis emphasized the importance of water management and conservation in New Mexico and upheld the district court's discretion in awarding costs and interest (paras 10-77).
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