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Facts

  • The case arose from an Inspection of Public Records Act (IPRA) request by A. Blair Dunn, counsel for Valley Meat Co., seeking records from the First Judicial District Court related to the Valley Meat case, including communications involving Judge Matthew Wilson and his staff. Additionally, Dunn requested information from Judge Wilson's personal election campaign Facebook page. The First Judicial District Court's custodian of records, Stephen Pacheco, responded, indicating that the court was producing all pertinent records except for those related to Judge Wilson's Facebook page and certain privileged communications (paras 5-8).

Procedural History

  • Fifth Judicial District Court, February 24: Valley Meat Co. filed an IPRA enforcement lawsuit against Judge Wilson and the First Judicial District Court, alleging failure to produce requested public records (para 9).
  • Fifth Judicial District Court, March 17: The Attorney General's office answered the complaint on behalf of the judicial defendants (para 10).
  • Fifth Judicial District Court, Partial Summary Judgment: Judge Hudson granted partial summary judgment in favor of the judicial defendants on all issues except the undisclosed e-mail exchange and the thirteen pages of e-mails disclosed after the commencement of the IPRA enforcement action (para 17).
  • Supreme Court of the State of New Mexico, Writ of Superintending Control: Following a remand for completion of adjudication on outstanding issues, the Supreme Court directed Judge Hudson to dismiss Judge Wilson as a named defendant and substitute Stephen Pacheco (paras 18-20).

Parties' Submissions

  • Petitioners (First Judicial District Court and Stephen Pacheco): Argued that IPRA actions directed at a district court’s records must be filed against the lawfully designated IPRA custodian and in the judicial district maintaining the records. Contended that certain communications, including those on a judge's personal social media, are not subject to IPRA (paras 2-3).
  • Respondent (Judge James M. Hudson): Ruled on the applicability of IPRA to the requested records and the judicial deliberation privilege, and addressed jurisdictional issues related to ordering relief against another district court (paras 14-15, 55-66).
  • Real Parties in Interest (Valley Meat Company, LLC, and Ricardo De Los Santos): Requested records under IPRA, including communications related to the Valley Meat case and information from Judge Wilson's personal election campaign Facebook page. Argued that their requests were improperly denied (paras 5-6).

Legal Issues

  • Whether contents of an officeholder’s personal election campaign social media website and internal decision-making communications are public records subject to IPRA (para 3).
  • Whether a district court has constitutional jurisdiction to order IPRA relief or sanctions against another district court (para 55).

Disposition

  • The Supreme Court directed Respondent James M. Hudson to vacate the previously entered summary judgment and to dismiss for lack of jurisdiction the complaint in Valley Meat Co., LLC v. Pacheco (para 70).

Reasons

  • The Supreme Court held that:
    IPRA actions directed at a district court’s records must be filed against the designated IPRA custodian and in the judicial district that maintains the records (para 2).
    Contents of an officeholder’s personal election campaign social media website and internal decision-making communications, such as preliminary drafts of judicial decisions, are not public records subject to mandatory disclosure under IPRA (para 3).
    A district court does not have constitutional jurisdiction to order IPRA relief or sanctions against another district court, as such actions are barred by the New Mexico Constitution (paras 55-66).
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