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 Plaintiff made an Inspection of Public Records Act (IPRA) request to the Office of the Attorney General (OAG) for billing records related to services provided by the Robles, Rael, and Anaya Law firm to the State of New Mexico, Attorney General’s Office from 2016-2018. The OAG provided 200 records with redactions on the narrative portions of the invoices, citing attorney-client privilege and attorney work product. The Plaintiff contested these redactions, arguing they were contrary to IPRA (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff: Argued that the redacted portions of the invoices should be disclosed under IPRA, contending that the redactions were not justified by attorney-client privilege or attorney work product protections (para 3).
• Defendants: Contended that the redacted narrative portions of the invoices were exempt from disclosure under IPRA as they were attorney-client privileged and protected attorney work product, especially since the litigation was ongoing and active (para 3).

Legal Issues

• Whether the redacted portions of the invoices for work performed by a law firm hired by the OAG are exempt from disclosure under the Inspection of Public Records Act as attorney-client privileged and/or protected attorney work product (para 1).

Disposition

• The district court’s order granting summary judgment in favor of Defendants, determining that the redacted portions of the invoices were exempt from disclosure under IPRA as attorney-client privileged and/or protected attorney work product, was affirmed (para 1).

Reasons

• The Court of Appeals, with Judge Jennifer L. Attrep writing the opinion, concurred by Judges Kristina Bogardus and Jacqueline R. Medina, found no error in the district court's decision. The court emphasized that it is the appellant's burden to persuade that the district court erred, which the Plaintiff did not achieve. The court addressed the Plaintiff's arguments regarding the public record status of the invoices, the applicability of attorney-client privilege and work-product doctrine, and the relevance of Schein v. Northern Rio Arriba Electric Cooperative, Inc., concluding none of these arguments merited reversal of the district court's decision. The court also noted the Plaintiff's failure to ensure that the material reviewed in camera by the district court was part of the record on appeal, which limited the court's ability to review the claim of error regarding the redacted material (paras 5-13).