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

• In July 1995, Albuquerque Commons Partnership (ACP) initiated a Section 1983 action against the City Council of the City of Albuquerque (the City), alleging that the City's adoption of a revised site zoning plan on ACP's leasehold property infringed upon ACP's substantive and procedural due process rights and constituted a taking in violation of the Fifth Amendment. A jury found in favor of ACP on both claims in February 2003, but damages for the takings claim were dismissed due to the election of remedies doctrine. A final judgment was entered against the City on the due process verdict for $8,349,095.00 (para 2).

Procedural History

• ACP II, 2008-NMSC-025: The Supreme Court reversed the Court of Appeals' judgment and affirmed the district court's judgment, holding that the City's decision lacked procedural fairness and did not comply with due process of law. The case was remanded to the Court of Appeals to address remaining claims, including the City's claim that the district court improperly awarded post-judgment interest at a statutory rate of "8 3/4% per annum" (para 4).
• ACP III, 2009-NMCA-065: The Court of Appeals affirmed the jury's award of damages and the district court's award of attorneys' fees and costs under 42 U.S.C. § 1988 but reversed the award of post-judgment interest, holding that the City was exempt from an award of post-judgment interest under Section 56-8-4(D) because Section 1961 does not apply to Section 1983 claims filed in state court (para 5).

Parties' Submissions

• Plaintiff (ACP): Argued that Section 56-8-4(D) is preempted by federal law as it obstructs the objectives of Section 1983, and that the Supremacy Clause of the United States Constitution requires an award of post-judgment interest. Additionally, ACP contended that Section 56-8-4(D) violates the Equal Protection Clause by creating inconsistent entitlements to post-judgment interest among civil rights victims (paras 3, 10-11).
• Defendant (City): Responded that "otherwise provided by statute" in Section 56-8-4(D) refers exclusively to state statutes, thus exempting the state and its political subdivisions from post-judgment interest on Section 1983 actions filed in state court. The City also argued that the bar on post-judgment interest does not violate the Supremacy Clause because Congress explicitly exempted state court judgments from post-judgment interest under Section 1961(c)(4) (paras 11).

Legal Issues

• Whether NMSA 1978, Section 56-8-4(D) bars an award of post-judgment interest against the state and its political subdivisions in a Section 1983 action (para 1).
• If post-judgment interest is not barred, whether federal law or state law establishes the proper rate of interest (para 1).

Disposition

• The Supreme Court concluded that the state and its political subdivisions are not exempt from post-judgment interest in Section 1983 actions, reversing the judgment of the Court of Appeals. It was determined that federal statute, 28 U.S.C. § 1961, provides for post-judgment interest in such actions and that the interest rate set forth in Section 1961 applies to Section 1983 actions filed in state court (para 1).

Reasons

• The Supreme Court, per Justice Petra Jimenez Maes, held that Section 56-8-4(D) does not exempt the state and its political subdivisions from post-judgment interest in Section 1983 actions because the Legislature intended for interest to be awarded "as otherwise provided by statute," which includes federal statutes like Section 1961. The Court reasoned that post-judgment interest is a crucial component of full compensation for plaintiffs deprived of their civil rights, ensuring that a monetary award retains its value over time. The Court also determined that the Legislature intended for the interest rate in Section 1961 to apply to Section 1983 actions filed in state court, promoting uniformity in the application of federal remedies (paras 8-25).