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, Gale Cooper, sued Lincoln County Sheriff's Department officials for unlawfully withholding public records concerning the 2003-2005 investigation into whether Pat Garrett really killed William Bonney, also known as "Billy the Kid," in 1881. After seven years of litigation, the district court ruled in favor of the Plaintiff, awarding nominal and punitive damages, costs, and past attorney fees under the New Mexico Inspection of Public Records Act (IPRA).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff: Argued that the district court erred by not considering and awarding statutory per diem damages available under IPRA.
• Defendants: Contended that statutory and punitive damages were resolved by a precedent case (Faber v. King) and that attorney fees were barred by the doctrine of accord and satisfaction.

Legal Issues

• Whether the district court erred in not awarding statutory per diem damages under IPRA.
• Whether punitive damages and attorney fees are permissible under IPRA.

Disposition

• The Court vacated the Plaintiff’s award of punitive damages and attorney fees.
• The Court affirmed the district court’s determination that statutory damages are not available.

Reasons

• The Court, consisting of Judges Linda M. Vanzi, James J. Wechsler, and M. Monica Zamora, reviewed the case de novo and based their decision on the interpretation of IPRA and relevant case law, particularly Faber v. King. They concluded that:
  Statutory damages under IPRA are not available when the custodian of records issues a timely denial, even if the denial is improper (paras 4-8).
  Punitive damages are not authorized under IPRA as clarified by the Supreme Court in Faber, thus vacating the punitive damage award (paras 10-12).
  Attorney fees previously settled in mediation cannot be awarded again, leading to the vacating of the "past attorney fees" award (paras 13-15).