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 Santa Fe Reporter Newspaper (the Newspaper) filed a claim against the City of Santa Fe (the City), alleging wrongful denial of its requests for documents under the New Mexico Inspection of Public Records Act (IPRA). The Newspaper sought disciplinary records, which the City refused to disclose, citing exemptions under IPRA.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellant/Cross-Appellee (The Newspaper): Argued that the district court erred in applying the IPRA "matters of opinion" exemption to deny the Newspaper's motion to compel and that the court had jurisdiction to address the Newspaper’s partial motion for summary judgment based on mootness (paras 3, 11).
• Defendants-Appellees/Cross-Appellants (The City and Records Custodian): Raised issues on cross-appeal regarding whether res judicata and collateral estoppel bar litigation of the Newspaper’s complaint, whether the district court erred by failing to set a procedural schedule or a trial date, and whether the district court erred in awarding the Newspaper attorney fees (paras 14, 17, 19).

Legal Issues

• Whether disciplinary records are subject to the "letters or memoranda that are matters of opinion in personnel files" exemption under IPRA (para 1).
• Whether the district court had jurisdiction to address the Newspaper’s partial motion for summary judgment based on mootness (para 1).
• Whether res judicata and collateral estoppel bar litigation of the Newspaper’s complaint (para 14).
• Whether the district court erred by failing to timely set a procedural schedule or a trial date (para 17).
• Whether the district court erred in awarding the Newspaper attorney fees (para 19).

Disposition

• The Court of Appeals affirmed the district court's decisions.

Reasons

• Judge Bogardus: Concluded that the district court did not err in applying the IPRA "matters of opinion" exemption to the Newspaper's request for disciplinary records. The court was bound by precedent and found no compelling reason to overturn existing case law. The court also found the issue regarding the "law enforcement" exemption moot since the City withdrew its assertion that the records were exempt under this provision. The City's arguments on cross-appeal regarding res judicata, collateral estoppel, procedural errors, and the awarding of attorney fees were either not preserved for review or lacked merit. The court emphasized the principles of stare decisis and the legislative intent behind IPRA to promote broad disclosure of public records, but noted that the "matters of opinion" exemption has remained essentially unchanged and supported by precedent (paras 3-9, 11-13, 14-22).