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

• In June 2007, the San Juan Agricultural Water Users Association (Plaintiff) submitted an Inspection of Public Records Act (IPRA) request to various entities including KNME-TV and the Regents of the University of New Mexico (Defendants), seeking documents related to the program "The Water Haulers" and its associated website. Defendants provided some, but not all, requested materials. The Plaintiff filed an enforcement complaint in August 2007, asserting that not all public records covered by the request were produced, specifically mentioning an eight-minute promotional video and master tapes related to the program (paras 2-5).

Procedural History

• San Juan Agric. Water Users Ass’n v. KNME-TV, 2010-NMCA-012: The Court of Appeals affirmed the district court's dismissal of Plaintiff's IPRA enforcement complaint.
• San Juan Agric. Water Users Ass’n v. KNME-TV, 2011-NMSC-011: The New Mexico Supreme Court reversed the Court of Appeals, reinstating Plaintiff's complaint and remanding for further proceedings (para 6).
• July 2012: The district court dismissed the case without prejudice for lack of prosecution, later reinstated it, and ordered mediation (para 7).

Parties' Submissions

• Plaintiff: Argued that Defendants had not produced all public records covered by the June 2007 request, specifically an eight-minute video and master tapes related to "The Water Haulers" program. Asserted that Defendants' failure to produce these materials violated IPRA (paras 4-5, 9).
• Defendants: Moved to dismiss the case, alleging Plaintiff lacked standing to enforce the June 2007 request. Later, provided additional documents and allowed inspection of previously denied records, citing changes in the law (paras 5, 8).

Legal Issues

• Whether a request for “all documents” related to a television broadcast program includes video recordings within its scope.
• Whether a request for statutory damages under IPRA can be premised on clarifications provided in subsequent communications or litigation documents.
• Whether damages, costs, and reasonable attorney fees are available where inspection of public records is denied based on exemptions later revealed to never have existed (para 1).

Disposition

• The Court of Appeals affirmed the district court's ruling that the request for “all documents” did not include video recordings and that liability for statutory damages must be based on the original request.
• The Court reversed the district court’s ruling regarding costs and attorney fees, remanding for further proceedings regarding both (para 1).

Reasons

• The Court found that the Plaintiff's June 2007 request, which specifically sought "all documents" related to "The Water Haulers" program, did not explicitly include video recordings, such as the eight-minute video or master tapes. The Court agreed with the district court that the specific language used in the request did not encompass these types of records. It also held that subsequent communications or litigation documents could not retroactively expand the scope of the original request. However, the Court reversed the district court's decision on costs and attorney fees, finding that Plaintiff was entitled to these for successful litigation that resulted in the production of responsive documents previously denied. The Court differentiated between the award of statutory damages under Section 14-2-11, which requires a determination of unreasonableness, and the award of costs and attorney fees under Section 14-2-12(D), which is mandated for a successful litigant in an IPRA enforcement action (paras 19-54).