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Citations - New Mexico Appellate Reports
Titus v. City of Albuquerque - cited by 57 documents

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Facts

  • Plaintiffs, a group of individuals and a class of others similarly situated, filed a class action complaint against the City of Albuquerque, its mayor, and Redflex Traffic Systems, Inc., challenging the legality and constitutionality of the City of Albuquerque’s “Safe Traffic Operations Program” (STOP) Ordinance.

Procedural History

  • Titus v. City of Albuquerque, 2011-NMCA-038: The Court of Appeals upheld the validity of the STOP Ordinance in favor of the City of Albuquerque.
  • Montoya v. City of Albuquerque, No. 29,838: Similar to Titus, the Court of Appeals upheld the STOP Ordinance.
  • The New Mexico Supreme Court granted certiorari for both Titus and Montoya but later quashed certiorari, leaving the Court of Appeals' decisions in place.

Parties' Submissions

  • Plaintiffs-Appellants: Challenged the procedure used by the district court in dismissing their case, arguing it was based on their supposed representation in the certified class in Montoya, without asserting that their interests differed from the Montoya class.
  • Defendants-Appellees (City of Albuquerque, Mayor, and Redflex Traffic Systems, Inc.): [Not applicable or not found]
  • Intervenors-Appellees: [Not applicable or not found]

Legal Issues

  • Whether the district court erred in dismissing the plaintiffs' class action complaint based on their representation in the certified class in Montoya.
  • Whether the merits of the plaintiffs' arguments against the STOP Ordinance were distinguishable from those considered in Titus and Montoya.

Disposition

  • The Court of Appeals affirmed the district court's dismissal of the plaintiffs' class action complaint, concluding that the merits of their arguments were either directly considered in Titus and Montoya or governed by the issues raised and analysis in those cases, rendering any procedural error by the district court moot.

Reasons

  • TIMOTHY L. GARCIA, Judge (with JAMES J. WECHSLER, Judge, and JONATHAN B. SUTIN, Judge concurring): The Court found that the plaintiffs' challenge to the STOP Ordinance had been adequately addressed in the prior decisions of Titus and Montoya. Since the Supreme Court quashed certiorari in both cases, the legal and constitutional validity of the STOP Ordinance as upheld by the Court of Appeals in those cases remained binding. The Court concluded that there were no new merits to be decided in the present case that were not already covered by Titus and Montoya. Consequently, any procedural errors made by the district court in dismissing the case were deemed moot, and the dismissal was affirmed based on the principles that an appellate court will affirm the district court if it is right for any reason and if affirmance is not unfair to the appellant (paras 1-2).
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