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

• The New Mexico Boys and Girls Ranch and El Ranchito de Los Ninos, collectively referred to as the Ranches, are facilities providing full-time care to children in need in New Mexico. They are licensed by the Children, Youth and Families Department (CYFD) as community homes. Previously, regulations required these facilities to obtain a pharmacy license for handling prescription medications. However, after 2014, new regulations did not include this requirement. The New Mexico Board of Pharmacy (the Board) later contended that the Ranches still needed a pharmacy license under the Pharmacy Act and its regulations, classifying them as "custodial care facilities" due to their handling of prescription medications (paras 2-5).

Procedural History

• District Court of Valencia County: Issued a permanent injunction against the Board, prohibiting it from enforcing the Pharmacy Act and its regulations against the Ranches, holding that the Act does not apply to community care homes licensed under 8.26.6 NMAC (para 1).

Parties' Submissions

• Plaintiffs-Appellees (The Ranches): Argued that they are not custodial care facilities but rather community homes regulated under 8.26.6 NMAC, which does not require a pharmacy license. They contended that requiring a pharmacy license would create duplicate oversight and that they do not provide extended health care but only occasionally administer prescribed medication (paras 4, 7).
• Defendant-Appellant (The Board): Argued that the Ranches are considered custodial care facilities under the Act and the Nursing Home Drug Control regulations, thus requiring a pharmacy license. The Board maintained that prescription medication is a dangerous drug under the Act, necessitating a license for storage and administration (paras 3, 8).

Legal Issues

• Whether the district court had subject matter jurisdiction to issue a decision on the Ranches’ complaint and grant a permanent injunction against the Board.
• Whether the Pharmacy Act requires the Ranches to hold a pharmacy license.
• Whether the Board acted within its authority when defining "custodial care facility" in its regulations (para 1).

Disposition

• The Court of Appeals affirmed the district court's decision, holding that the Pharmacy Act does not apply to community care homes licensed under 8.26.6 NMAC (para 34).

Reasons

• The Court of Appeals, with Judge Jacqueline R. Medina writing the opinion, concurred by Chief Judge J. Miles Hanisee and Judge Kristina Bogardus, found that:
  The district court had subject matter jurisdiction as there was an actual controversy with direct and imminent harm to the Ranches due to the Board’s regulations, establishing standing and ripeness for judicial intervention (paras 9-15).
  The district court did not abuse its discretion in granting declaratory and injunctive relief, as the Ranches faced an imminent injury with no adequate remedy at law, justifying the injunction (paras 16-18).
  Community homes are not custodial care facilities under the Act, as the primary purpose of these homes is to care for children's basic needs, not to provide extended health care or prescribe medications. The Court applied the doctrine of ejusdem generis, concluding that the Board's interpretation was overly broad and not in line with the Legislature's intent (paras 19-26).
  The Board exceeded its regulatory authority by expanding the definition of "custodial care facility" beyond the Legislature's intent, rendering its definition void (paras 31-33).
  The Court's analysis emphasized the distinct nature of community homes from custodial care facilities and the existing regulatory oversight by CYFD, which includes health and safety standards for administering and storing medication, negating the need for a pharmacy license under the Act (paras 27-30).