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 case concerns the constitutionality of New Mexico’s textbook loan program, which allows the state to lend textbooks to students attending both public and private schools. The program was challenged on the grounds that it violated several provisions of the New Mexico Constitution by providing public funds to support private schools, including religious ones.

Procedural History

• Moses v. Skandera (Moses II), 2015-NMSC-036: Held that lending textbooks to private school students violated Article XII, Section 3 of the New Mexico Constitution.
• N.M. Ass’n of Non-public Sch. v. Moses, 137 S. Ct. 2325 (2017) (mem.): The United States Supreme Court vacated the judgment and remanded the case for further consideration in light of Trinity Lutheran Church of Columbia, Inc. v. Comer.

Parties' Submissions

• Plaintiffs-Petitioners: Argued that the Instructional Material Law (IML) violates the New Mexico Constitution by distributing public funds to private schools.
• Defendant-Respondent and Defendants/Intervenors-Respondents: Contended that the textbook loan program does not violate the New Mexico Constitution and that excluding private schools from the program would violate the Free Exercise Clause of the First Amendment to the United States Constitution.

Legal Issues

• Whether the textbook loan program violates Article XII, Section 3 of the New Mexico Constitution, which prohibits the use of public funds for the support of any sectarian, denominational, or private school.
• Whether the textbook loan program violates Article IV, Section 31 and Article IX, Section 14 of the New Mexico Constitution.
• Whether excluding private schools from the textbook loan program violates the Free Exercise Clause of the First Amendment to the United States Constitution.

Disposition

• The Supreme Court of the State of New Mexico held that the textbook loan program does not violate Article XII, Section 3, Article IV, Section 31, or Article IX, Section 14 of the New Mexico Constitution and reinstated the provisions of the IML that allow private school students to participate in the textbook loan program.

Reasons

• The Court concluded that the textbook loan program provides a generally available public benefit that does not result in the use of public funds in support of private schools as prohibited by Article XII, Section 3. The program was found to be consistent with the state's interest in promoting education and eliminating illiteracy, with any benefit to private schools being purely incidental. The Court also determined that the program does not result in any appropriation to a person or entity not under the absolute control of the state as prohibited by Article IV, Section 31, nor does it constitute a donation to any person or entity as prohibited by Article IX, Section 14. The decision was made in light of evolving First Amendment jurisprudence, particularly the Supreme Court's decision in Trinity Lutheran, which necessitated a reconsideration of the state's previous interpretation of Article XII, Section 3 to avoid constitutional concerns under the Free Exercise Clause.