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

• Attorney Daniel Faber filed a federal lawsuit alleging gender discrimination in salaries within the Attorney General's Office. During the litigation, a stay on discovery was issued by the federal court. Amidst this, Faber requested employment data from the Attorney General’s Office under the New Mexico Inspection of Public Records Act (IPRA), which was denied on the grounds of circumventing the discovery process. Faber then sought enforcement of his IPRA request and damages in state court, arguing the denial was wrongful (paras 2-4).

Procedural History

• District Court: Found the Attorney General violated IPRA by denying Faber's request and issued a writ of mandamus for compliance. Damages were to be considered later (para 4).
• Court of Appeals: Held that damages for enforcement of a denied IPRA request are governed by Section 14-2-12(D), not Section 14-2-11(C), and remanded the case to determine the nature of compensatory damages (para 6).

Parties' Submissions

• Plaintiff-Respondent (Faber): Argued that statutory per diem damages should apply for wrongful denial of IPRA requests, similar to the damages awarded for failure to timely respond under Section 14-2-11(C) (para 5).
• Defendant-Petitioner (Attorney General): Contended that the Legislature did not intend for statutory damages to be awarded under Section 14-2-12(D) for wrongful denial of IPRA requests and that punitive damages against the State are unavailable without an express declaration (paras 13, 22).

Legal Issues

• Whether Section 14-2-12(D) of the IPRA authorizes the award of statutory or punitive damages for wrongful denial of document requests (paras 11, 22).
• Whether Faber is eligible for nominal damages under IPRA (para 36).

Disposition

• The Supreme Court held that Section 14-2-12(D) does not permit punitive or statutory damages, only allowing for a writ of mandanus, an injunction, actual damages, costs, and attorneys’ fees. It also determined that Faber is not eligible for nominal damages (paras 41-42).

Reasons

• MAES, Justice (with VIGIL, C.J., BOSSON, CHÁVEZ, and DANIELS, JJ., concurring):
  Statutory and Punitive Damages: The Court found that the plain language, purpose, and history of IPRA indicate that the Legislature did not intend for punitive or statutory damages to be awarded under Section 14-2-12(D). The Court emphasized that statutory damages are specified without requiring proof of actual injury and noted that such specificity is absent in Section 14-2-12(D) (paras 14-15, 22-26).
  Compensatory Damages: The Court concluded that IPRA's purpose is served by allowing compensatory damages, costs, and attorneys’ fees for wrongful denial of requests, aligning with the legislative intent to ensure access to public records and accountability of public servants without unduly burdening taxpayers (paras 27-35).
  Nominal Damages: The Court determined that Faber is not eligible for nominal damages under IPRA, as the statute provides for actual damages, costs, and attorneys’ fees, which are sufficient to compensate and incentivize compliance with IPRA without the need for nominal damages (paras 36-40).