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 case revolves around the 2021 Albuquerque mayoral race, where Sheriff Manny Gonzales sought to qualify for public financing. The City Clerk, acting in his official capacity, denied Sheriff Gonzales's application for public financing due to allegations of fraud. This denial led to Sheriff Gonzales claiming that the Defendants' procedures deprived him of due process (para 2).

Procedural History

• Gonzales v. Watson (Gonzales I), 2024-NMCA-033, ___ P.3d ___ (A-1-CA-39971, Jan. 23, 2024): The district court's determination that Sheriff Gonzales’s due process rights had been violated was reversed.

Parties' Submissions

• Plaintiff-Appellant/Cross-Appellee (Sheriff Gonzales): Argued that the district court erred by determining that legal fees in the Due Process case were not recoverable as damages, by not awarding damages for lost days of fundraising, and by dismissing his N.M. Constitution Bill of Rights and Inspection of Public Records claims (para 1).
• Defendants-Appellees/Cross-Appellants (City Clerk and the City of Albuquerque): Argued on cross-appeal that the district court erred in concluding issue preclusion applied to this case based on the first case between the parties, abused its discretion in applying issue preclusion, and erred in awarding Sheriff Gonzales all his claimed fees despite only partially prevailing (para 1).

Legal Issues

• Whether the district court erred in applying issue preclusion based on the first case between the parties.
• Whether the district court abused its discretion in applying issue preclusion.
• Whether the district court erred in awarding Sheriff Gonzales all his claimed fees despite only partially prevailing.
• Whether the district court erred in determining that legal fees in the Due Process case were not recoverable as damages.
• Whether the district court erred in not awarding damages for lost days of fundraising.
• Whether the district court erred in dismissing Sheriff Gonzales's N.M. Constitution Bill of Rights and Inspection of Public Records claims.

Disposition

• The district court's decisions to grant preclusive effect for Sheriff Gonzales’s CRA due process claim and to grant Sheriff Gonzales’s costs, attorney fees, and nominal damages were reversed.
• The district court's decision to dismiss Sheriff Gonzales’s remaining claims was affirmed.

Reasons

• BUSTAMANTE, Judge, retired, sitting by designation, HANISEE, Judge, and YOHALEM, Judge, concurring: The court reversed the district court's decisions on issue preclusion and costs because the basis for issue preclusion was overturned in Gonzales I, meaning there was no longer any basis for issue preclusion, attorney fees, costs, and damages (paras 6-7). The court found Sheriff Gonzales's arguments regarding the awarding of costs for the Due Process case and for his lost days of fundraising, as well as Defendants' argument regarding the awarding of all of Sheriff Gonzales's fees despite his partial success, to be moot due to the reversal of the district court's decision on issue preclusion (para 7). The court concluded that Sheriff Gonzales did not meet his burden to demonstrate an error on the part of the district court that requires reversal regarding his CRA Bill of Rights claim or his IPRA claim, due to insufficient argumentation and lack of substantive support in his briefing (para 8).