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

• Greentree Solid Waste Authority (Greentree) entered into joint powers agreements with Lincoln County and several municipalities in 1991 and 1992, granting it the authority to manage solid waste collection in the County's unincorporated areas. In 2005, the Alto Lakes Water and Sanitation District (the District) was established to manage waste in a specific unincorporated area, leading Greentree to claim that the District's creation and operation violated its contractual rights. Greentree sought a declaratory judgment, an injunction against the District and the County, and damages from the County for breach of contract (paras 1, 3-7).

Procedural History

• District Court of Santa Fe County, Sarah M. Singleton, District Judge: Granted summary judgment to the District and the County, dismissing all of Greentree's claims (para 2).

Parties' Submissions

• Plaintiff-Appellant (Greentree): Argued that joint powers agreements and ordinances granted it exclusive authority to collect solid waste in the unincorporated areas of the County, and that the creation of the District violated these agreements. Sought an injunction to prevent the District from collecting waste and damages from the County for breach of contract (paras 1, 8-10).
• Defendants-Appellees (District and County): Contended that Greentree did not have an exclusive right to serve the District and that its remedy for loss of the contract for services in the District was either to protest the formation of the District or to file a grievance under the Procurement Code. Joined in motions to dismiss Greentree’s complaint for failure to state a claim and for summary judgment (para 9).

Legal Issues

• Whether Greentree had exclusive authority to manage solid waste in the unincorporated parts of Lincoln County under the joint powers agreements.
• Whether the summary judgment in favor of the County and the District impaired Greentree's contractual rights in violation of the New Mexico Constitution.

Disposition

• The Court of Appeals affirmed the summary judgment entered in favor of the County and the District, dismissing all of Greentree's claims (para 29).

Reasons

• Per Michael E. Vigil, Chief Judge (James J. Wechsler, Judge, and Cynthia A. Fry, Judge, concurring): The court found that Greentree did not have exclusive authority over solid waste management in the area covered by the District. The creation of the District under the Water and Sanitation District Act was a statutory scheme over which the County had no control, and Greentree's contract with the County did not preclude the District's operation of a solid waste system. Furthermore, the court held that the summary judgment did not impair Greentree's contractual rights, as waste removal is subject to legislative regulation and Greentree's rights were not removed from state restriction by making a contract about them. The court declined to address additional arguments made by Greentree due to their undeveloped nature or because they were raised for the first time in a reply brief (paras 13-28).