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 New Mexico Public Regulation Commission (the Commission) authorized Running Bear, d/b/a Rocky Mountain EMS (Rocky Mountain), to provide non-emergency ambulance transport services in Bernalillo County. Rocky Mountain filed for bankruptcy shortly after, and American Medical Response (AMR) purchased Rocky Mountain's operating license. The appellants, Bernalillo County Health Care Corporation, d/b/a Albuquerque Ambulance Service (Albuquerque Ambulance), and Superior Ambulance Company (Superior), challenged the Commission's decision, arguing it was arbitrary and capricious for failing to meet statutory requirements. AMR, having acquired Rocky Mountain's authority, intervened in the appeal (paras 1-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellants: Argued that the Commission's final order was arbitrary and capricious because Rocky Mountain did not meet the statutory requirements for fitness, willingness, and ability to provide the service, nor compliance with applicable laws and regulations (para 2).
• Intervening Party (AMR): Contended that fitness issues related to Rocky Mountain were moot following AMR's purchase of the operating license and that the only remaining issue, public need, was supported by substantial evidence (para 7).

Legal Issues

• Whether the Commission's final order authorizing Rocky Mountain to provide non-emergency ambulance transport services was arbitrary and capricious (para 3).
• Whether the issues regarding Rocky Mountain's fitness, willingness, and ability to provide services were moot following the purchase by AMR (para 11).
• Whether substantial evidence existed to show that Rocky Mountain was fit, willing, and able to provide non-emergency services at the time of application (para 15).
• Whether the Commission's interpretation of compliance with applicable laws and regulations was too narrow and conflicted with the goal of the Act (para 22).
• Whether there was substantial evidence of a demonstrated public need for non-emergency services in Bernalillo County (para 26).

Disposition

• The Supreme Court annulled and vacated the Commission's final order, revoking the original certificate endorsement allowing Rocky Mountain to provide non-emergency ambulance transport services in Bernalillo County (para 29).

Reasons

• The Supreme Court, per Chief Justice Petra Jimenez Maes, held that the issues regarding Rocky Mountain's fitness were not moot despite AMR's acquisition of the certificate of authority. The Court found that the Commission's decision was arbitrary and capricious, as substantial evidence did not support that Rocky Mountain was fit, willing, and able to provide services or had complied with applicable laws and regulations at the time of application. The Court criticized the Commission's narrow interpretation of compliance with applicable laws and regulations, which conflicted with the Act's goals. However, the Court acknowledged substantial evidence of public need for additional non-emergency transport services in Bernalillo County but emphasized that all statutory criteria must be met for the issuance of a certificate (paras 11-28).