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 involves two requests for records submitted by the Plaintiff to the Defendant under the Inspection of Public Records Act (IPRA). The first request sought all laws pertaining specifically to property inspections by the San Miguel County Assessor’s Office. The second request sought documents responsive to specific hypothetical legal situations posed by the Plaintiff. The Defendant responded to both requests but did not provide the documents the Plaintiff sought, leading to the Plaintiff filing a complaint for damages under IPRA (paras 2-4).

Procedural History

• District Court: Denied Defendant’s motion to dismiss the complaint and later granted Defendant’s motion for summary judgment, dismissing Plaintiff’s complaint without prejudice. Plaintiff’s motion for reconsideration was also denied (para 5).

Parties' Submissions

• Plaintiff: Argued that summary judgment was granted in error as Defendant violated IPRA by not providing responsive documents to his requests (para 6).
• Defendant: Contended that Plaintiff’s requests did not seek public records as defined in IPRA, asserting that the first request sought laws and regulations which are not Defendant’s records and the second request sought answers to hypothetical situations not governed by IPRA (para 7).

Legal Issues

• Whether the district court erred by granting summary judgment in favor of the Defendant on the basis that the Defendant did not violate IPRA by failing to provide documents responsive to the Plaintiff’s requests (paras 6-7).
• Whether Plaintiff’s requests identified the records sought with reasonable particularity under IPRA (paras 12-14).

Disposition

• The Court of Appeals affirmed the district court’s orders granting summary judgment in favor of the Defendant and denying Plaintiff’s motion for reconsideration (para 1).

Reasons

• The Court of Appeals, with Judges Henderson, Hanisee, and Bustamante (partially concurring and partially dissenting), held that the Plaintiff’s requests did not identify records with reasonable particularity as required by IPRA. The Court found that the first request sought laws and statutes, which are publicly available and not specific records held by the Defendant. The second request sought answers to hypothetical legal situations, which would require the Defendant to create new documents, not covered under IPRA. The Court concluded that since the requests did not meet the particularity requirement of IPRA, the Defendant did not violate IPRA by failing to provide the requested documents. Judge Bustamante concurred in part and dissented in part, agreeing with the dismissal based on the second request but expressing concern that the majority’s rationale might mislead regarding the particularity requirement. He also dissented from the majority’s decision to affirm the dismissal of the entire complaint, suggesting that part of the first request could reasonably describe internal guidelines or materials used by the Defendant, which would be covered by IPRA (paras 6-26).