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

• A real property owner, Northwest Villages, LLC, sought to recover $84,812.73 in property taxes paid for the 2007 tax year, along with attorneys fees and costs, from Santa Fe County Treasurer and Assessor. The owner filed four claims: a Claim of Refund, a Violation of the “Equal & Uniform” Clause of the New Mexico Constitution, a Claim to Amend Tax Schedules, and Constructive Fraud.

Procedural History

• District Court: Dismissed the Claim of Refund due to the statute of limitations but allowed the remaining counts to proceed.
• Court of Appeals: Denied the County's Request for Interlocutory Appeal.
• Supreme Court of New Mexico: Granted certiorari to review the district court's decision to allow the remaining counts to proceed.

Parties' Submissions

• County Assessor and Treasurer: Argued that the statute of limitations for a tax refund bars any alternative claim for essentially the same relief, that calling relief “equitable” does not exempt it from the statute of limitations, and that sovereign immunity bars recovery from the County unless a statute explicitly waives the immunity.
• Northwest Villages, LLC: [Not applicable or not found]

Legal Issues

• Whether the statute of limitations for a tax refund bars any alternative claim for essentially the same relief.
• Whether sovereign immunity bars recovery from the County in the absence of an explicit statutory waiver.

Disposition

• The Supreme Court reversed the district court’s order allowing Respondent’s alternative claims to proceed and dismissed Respondent’s claims in their entirety.

Reasons

• Per RICHARD C. BOSSON, Justice (CHARLES W. DANIELS, Chief Justice, PATRICIO M. SERNA, Justice, PETRA JIMENEZ MAES, Justice, EDWARD L. CHÁVEZ, Justice concurring):
  The Court found that the statute of limitations for a tax refund claim also applies to any alternative claim for the same relief, thereby barring the Respondent's remaining claims. It held that allowing claims beyond those described by statute would undermine the statutory timeline and deadline established by the Tax Code. The Court also addressed and rejected each of Respondent’s other claims on their merits, including the constitutionality claim, the tax schedule claim, and the constructive fraud claim, citing statutory provisions, case law, and principles of sovereign immunity and statutory interpretation.