ripeness doctrine (New Mexico) · Go Syfert
← New Mexico issues

ripeness doctrine in New Mexico

22 New Mexico opinions name it 2 courts 1991–2022 3 in the last five years

The cases below were cited by New Mexico courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
American Civil Liberties Union v. City of Albuquerquegreen
nm · 2008 · cited in 3 New Mexico opinions naming this issue, 2016–2016
2 sentences

2016See also 17 ACLU of N.M., 2008-NMSC-045, ¶ 10 (observing that analysis of justiciability 18 principles in New Mexico have long been guided by federal practice).

2016See also ACLU of N.M., 2008-NMSC-045, ¶ 10 (observing that analysis of justiciability principles in New Mexico have long been guided by federal practice).

33
Rio Grande Kennel Club v. City of Albuquerquegreen
nmctapp · 2008 · cited in 3 New Mexico opinions naming this issue, 2016–2016
2 sentences

2016See Rio Grande Kennel Club v. City of Albuquerque, 2008-NMCA-093, ¶ 24 , 144 N.M. 636 , 190 P.3d 1131 (rejecting as premature, under ripeness principles, a facial claim against a regulation that the city had yet to enforce); 15 Moore’s Federal Practice § 101.80[4] at 101-345 (“The existence of a contingency is sufficient to elicit a finding that the issue is not yet ripe for review.”). {28} The second step in the ripeness analysis is whether, and to what extent, the parties will endure hardship if a decision is withheld.

2016See Rio Grande Kennel Club v. City of Albuquerque, 2008-NMCA-093, ¶ 24 , 144 N.M. 636 , 190 P.3d 1131 (rejecting as premature, under ripeness principles, a facial claim against a regulation that the city had yet to enforce); 15 Moore’s Federal Practice § 101.80[4] at 101-345 (“The existence of a contingency is sufficient to elicit a finding that the issue is not yet ripe for review.”). {28} The second step in the ripeness analysis is whether, and to what extent, the parties will endure hardship if a decision is withheld.

33
Casanova v. Marathon Corp.green
cadc · 2009 · cited in 3 New Mexico opinions naming this issue, 2013–2014
2 sentences

2014“The ripeness doctrine exists to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements.” City of Sunland Park v. Macias, 2003-NMCA-098, ¶ 23 , 134 N.M. 216 , 75 P.3d 816 (internal quotation marks and citation omitted). “[A]n issue may be ripe where the threat of harm [is] sufficiently direct and immediate as to render the issue appropriate for judicial review at this stage.” Id. (internal quotation marks and citation omitted). {60} Plaintiffs rely on Casanova v. Marathon Corp., 256 F.R.D. 11, 14 (D.D.C. 2009), for the proposition

2013“The ripeness doctrine exists to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements.” City of Sunland Park v. Macias, 2003-NMCA-098, ¶ 23 , 134 N.M. 216 , 75 P.3d 816 (internal quotation marks and citation omitted). “[A]n issue may be ripe where the threat of harm [is] sufficiently direct and immediate as to render the issue appropriate for judicial review at this stage.” Id. (internal quotation marks and citation omitted). {60} Plaintiffs rely on Casanova v. Marathon Corp., 256 F.R.D. 11, 14 (D.D.C. 2009), for the proposition

33
AFSCME v. Bd. of Cty. Comm'rs of Bernalillo Cty.green
nm · 2016 · cited in 2 New Mexico opinions naming this issue, 2022–2022
2 sentences

2022See AFSCME, 2016-NMSC-017, ¶ 28 (“The second step in the ripeness analysis is whether, and to what extent, the parties will endure hardship if a decision is withheld.”).

2022See AFSCME, 2016-NMSC-017, ¶ 28 (“The second step in the ripeness analysis is whether, and to what extent, the parties will endure hardship if a decision is withheld.”).

22
City of Sunland Park v. MacIasgreen
nmctapp · 2003 · cited in 8 New Mexico opinions naming this issue, 2013–2019
2 sentences

2019“The basic 5 purpose of ripeness law is and always has been to conserve judicial machinery for 6 problems which are real and present or imminent, not to squander it on abstract or 7 hypothetical or remote problems.” Titus v. City of Albuquerque, 2011-NMCA-038 , 8 ¶ 44, 149 N.M. 556 , 252 P.3d 780 (internal quotation marks and citation omitted). 9 “The ripeness doctrine exists to prevent the courts, through avoidance of premature 10 adjudication, from entangling themselves in abstract disagreements.” City of 11 Sunland Park v. Macias, 2003-NMCA-098, ¶ 23 , 134 N.M. 216 , 75 P.3d 816 12 (interna

2019“The basic 5 purpose of ripeness law is and always has been to conserve judicial machinery for 6 problems which are real and present or imminent, not to squander it on abstract or 7 hypothetical or remote problems.” Titus v. City of Albuquerque, 2011-NMCA-038 , 8 ¶ 44, 149 N.M. 556 , 252 P.3d 780 (internal quotation marks and citation omitted). 9 “The ripeness doctrine exists to prevent the courts, through avoidance of premature 10 adjudication, from entangling themselves in abstract disagreements.” City of 11 Sunland Park v. Macias, 2003-NMCA-098, ¶ 23 , 134 N.M. 216 , 75 P.3d 816 12 (interna

18
New Mexico Industrial Energy Consumers v. New Mexico Public Service Commissiongreen
nm · 1991 · cited in 2 New Mexico opinions naming this issue, 1998–2022
2 sentences

2022Comm’n, 1991-NMSC-018 , ¶ 25, 111 N.M. 622 , 808 P.2d 592 (stating that the purpose of the ripeness requirement “is and always has been to conserve judicial machinery for problems which are real and present or imminent, not to squander it on abstract or hypothetical or remote problems”). {6} For the reasons set forth above, we affirm. {7} IT IS SO ORDERED.

2022Comm’n, 1991-NMSC-018 , ¶ 25, 111 N.M. 622 , 808 P.2d 592 (stating that the purpose of the ripeness requirement “is and always has been to conserve judicial machinery for problems which are real and present or imminent, not to squander it on abstract or hypothetical or remote problems”). {6} For the reasons set forth above, we affirm. {7} IT IS SO ORDERED.

12
NEW ENERGY ECONOMY, INC. v. Shoobridgegreen
nm · 2010 · cited in 2 New Mexico opinions naming this issue, 2012–2015
2 sentences

2015State Corp. Comm’n, 1998-NMSC-032, ¶ 8 , 125 N.M. 798 , 965 P.2d 917 (observing that the doctrine of ripeness “serves to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements over administrative policies, and also to protect the agencies from judicial interference until an administrative decision has been formalized and its effects felt in a concrete way by the challenging parties” (internal quotation marks and citation omitted)); New Energy Econ., 2010-NMSC-049, ¶ 17 (“One of the prerequisites of ... a declaratory judgment action

2012Before we address whether these appellate procedures provide sufficient due process, we must first answer whether Tri-State’s challenge is ripe for review. {48} In New Energy Economy, this Court recently reviewed a ripeness challenge to an administrative rule that had yet to be promulgated. 2010-NMSC-049, ¶ 1 .

12
Mills v. New Mexico State Board of Psychologist Examinersgreen
nm · 1997 · cited in 1 New Mexico opinions naming this issue, 2013–2013
2 sentences

2013See, 8 e.g., Mills v. New Mexico State Bd. of Psychologist Exam’rs, 1997-NMSC-028 , ¶¶ 10- 9 11, 123 N.M. 421 , 941 P.2d 502 (discussing the two-pronged jurisdictional question 10 presented about the administrative appeal and deciding that the due process claim was 11 properly brought in a petition for writ of certiorari and that the due process claim was 12 ripe for review on the basis that the agency’s action was sufficiently final, given that, 13 otherwise, the plaintiff would be denied judicial review); Manning v. Mining & 14 Minerals Div., 2006-NMSC-027, ¶ 54 , 140 N.M. 528 , 144 P.3d 87

2013See, 8 e.g., Mills v. New Mexico State Bd. of Psychologist Exam’rs, 1997-NMSC-028 , ¶¶ 10- 9 11, 123 N.M. 421 , 941 P.2d 502 (discussing the two-pronged jurisdictional question 10 presented about the administrative appeal and deciding that the due process claim was 11 properly brought in a petition for writ of certiorari and that the due process claim was 12 ripe for review on the basis that the agency’s action was sufficiently final, given that, 13 otherwise, the plaintiff would be denied judicial review); Manning v. Mining & 14 Minerals Div., 2006-NMSC-027, ¶ 54 , 140 N.M. 528 , 144 P.3d 87

11
Harris v. Revenue Division of the Taxation & Revenue Departmentgreen
nmctapp · 1987 · cited in 1 New Mexico opinions naming this issue, 1991–1991
2 sentences

1991Dep’t, 105 N.M. 721, 722 , 737 P.2d 80, 81 (Ct.App.1987).

1991Dep’t, 105 N.M. 721, 722 , 737 P.2d 80, 81 (Ct.App.1987).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Mexico. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
U S West Communications, Inc. v. New Mexico State Corp. green
nm · 1998
2 sentences

2015State Corp. Comm’n, 1998-NMSC-032, ¶ 8 , 125 N.M. 798 , 965 P.2d 917 (observing that the doctrine of ripeness “serves to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements over administrative policies, and also to protect the agencies from judicial interference until an administrative decision has been formalized and its effects felt in a concrete way by the challenging parties” (internal quotation marks and citation omitted)); New Energy Econ., 2010-NMSC-049, ¶ 17 (“One of the prerequisites of ... a declaratory judgment action

2015State Corp. Comm’n, 1998-NMSC-032, ¶ 8 , 125 N.M. 798 , 965 P.2d 917 (observing that the doctrine of ripeness “serves to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements over administrative policies, and also to protect the agencies from judicial interference until an administrative decision has been formalized and its effects felt in a concrete way by the challenging parties” (internal quotation marks and citation omitted)); New Energy Econ., 2010-NMSC-049, ¶ 17 (“One of the prerequisites of ... a declaratory judgment action

32003–2015
Smith International, Inc. v. Egle Group, LLC green
ca5 · 2007
2 sentences

2014Pa. March 15, 2005), for the proposition stated in that case that “the mere expenditure of counsel fees does not constitute the accrual of a cause of action for indemnification.” (Internal quotation marks and citation omitted.) And Plaintiffs also rely on Smith International, Inc. v. The Egle Group, LLC, 490 F.3d 380 (5th Cir. 2007), and Bellevue v. Kafka, Nos. 92 C 4589, 92 C 6663, 1994 WL 127213 (N.D.

2013Pa. March 15, 2005), for the proposition stated in that case that “the mere expenditure of counsel fees does not constitute the accrual of a cause of action for indemnification.” (Internal quotation marks and citation omitted.) And Plaintiffs also rely on Smith International, Inc. v. The Egle Group, LLC, 490 F.3d 380 (5th Cir. 2007), and Bellevue v. Kafka, Nos. 92 C 4589, 92 C 6663, 1994 WL 127213 (N.D.

32013–2014
Abbott Laboratories v. Gardner red
scotus · 1967
2 sentences

2010State Corp. Comm’n, 1998-NMSC-032, ¶ 8 , 125 N.M. 798 , 965 P.2d 917 (quoting Abbott, 387 U.S. at 148-49 , 87 S.Ct. 1507 (internal quotation marks omitted)). {16} The plaintiffs respond that a ripeness analysis is not applicable in this case because the federal doctrine of ripeness relied on by Petitioners has no basis in the New Mexico Constitution.

2010State Corp. Comm’n, 1998-NMSC-032, ¶ 8 , 125 N.M. 798 , 965 P.2d 917 (quoting Abbott, 387 U.S. at 148-49 , 87 S.Ct. 1507 (internal quotation marks omitted)). {16} The plaintiffs respond that a ripeness analysis is not applicable in this case because the federal doctrine of ripeness relied on by Petitioners has no basis in the New Mexico Constitution.

31991–2010
Titus v. City of Albuquerque green
nmctapp · 2011
2 sentences

2019“The basic 5 purpose of ripeness law is and always has been to conserve judicial machinery for 6 problems which are real and present or imminent, not to squander it on abstract or 7 hypothetical or remote problems.” Titus v. City of Albuquerque, 2011-NMCA-038 , 8 ¶ 44, 149 N.M. 556 , 252 P.3d 780 (internal quotation marks and citation omitted). 9 “The ripeness doctrine exists to prevent the courts, through avoidance of premature 10 adjudication, from entangling themselves in abstract disagreements.” City of 11 Sunland Park v. Macias, 2003-NMCA-098, ¶ 23 , 134 N.M. 216 , 75 P.3d 816 12 (interna

2019“The basic 5 purpose of ripeness law is and always has been to conserve judicial machinery for 6 problems which are real and present or imminent, not to squander it on abstract or 7 hypothetical or remote problems.” Titus v. City of Albuquerque, 2011-NMCA-038 , 8 ¶ 44, 149 N.M. 556 , 252 P.3d 780 (internal quotation marks and citation omitted). 9 “The ripeness doctrine exists to prevent the courts, through avoidance of premature 10 adjudication, from entangling themselves in abstract disagreements.” City of 11 Sunland Park v. Macias, 2003-NMCA-098, ¶ 23 , 134 N.M. 216 , 75 P.3d 816 12 (interna

12019–2019
Titus v. City of Albuquerque green
nmctapp · 2011
1 sentence

2019“The basic 5 purpose of ripeness law is and always has been to conserve judicial machinery for 6 problems which are real and present or imminent, not to squander it on abstract or 7 hypothetical or remote problems.” Titus v. City of Albuquerque, 2011-NMCA-038 , 8 ¶ 44, 149 N.M. 556 , 252 P.3d 780 (internal quotation marks and citation omitted). 9 “The ripeness doctrine exists to prevent the courts, through avoidance of premature 10 adjudication, from entangling themselves in abstract disagreements.” City of 11 Sunland Park v. Macias, 2003-NMCA-098, ¶ 23 , 134 N.M. 216 , 75 P.3d 816 12 (interna

12019–2019
Manning v. Mining & Minerals Division of the Energy, Minerals, & Natural Resources Department green
nm · 2006
2 sentences

2013See, 8 e.g., Mills v. New Mexico State Bd. of Psychologist Exam’rs, 1997-NMSC-028 , ¶¶ 10- 9 11, 123 N.M. 421 , 941 P.2d 502 (discussing the two-pronged jurisdictional question 10 presented about the administrative appeal and deciding that the due process claim was 11 properly brought in a petition for writ of certiorari and that the due process claim was 12 ripe for review on the basis that the agency’s action was sufficiently final, given that, 13 otherwise, the plaintiff would be denied judicial review); Manning v. Mining & 14 Minerals Div., 2006-NMSC-027, ¶ 54 , 140 N.M. 528 , 144 P.3d 87

2013See, 8 e.g., Mills v. New Mexico State Bd. of Psychologist Exam’rs, 1997-NMSC-028 , ¶¶ 10- 9 11, 123 N.M. 421 , 941 P.2d 502 (discussing the two-pronged jurisdictional question 10 presented about the administrative appeal and deciding that the due process claim was 11 properly brought in a petition for writ of certiorari and that the due process claim was 12 ripe for review on the basis that the agency’s action was sufficiently final, given that, 13 otherwise, the plaintiff would be denied judicial review); Manning v. Mining & 14 Minerals Div., 2006-NMSC-027, ¶ 54 , 140 N.M. 528 , 144 P.3d 87

12013–2013
Manning v. ENERGY, MINERALS green
nm · 2006
1 sentence

2013See, 8 e.g., Mills v. New Mexico State Bd. of Psychologist Exam’rs, 1997-NMSC-028 , ¶¶ 10- 9 11, 123 N.M. 421 , 941 P.2d 502 (discussing the two-pronged jurisdictional question 10 presented about the administrative appeal and deciding that the due process claim was 11 properly brought in a petition for writ of certiorari and that the due process claim was 12 ripe for review on the basis that the agency’s action was sufficiently final, given that, 13 otherwise, the plaintiff would be denied judicial review); Manning v. Mining & 14 Minerals Div., 2006-NMSC-027, ¶ 54 , 140 N.M. 528 , 144 P.3d 87

12013–2013
Gunaji v. MacIas green
nm · 2001
2 sentences

2013See, 8 e.g., Mills v. New Mexico State Bd. of Psychologist Exam’rs, 1997-NMSC-028 , ¶¶ 10- 9 11, 123 N.M. 421 , 941 P.2d 502 (discussing the two-pronged jurisdictional question 10 presented about the administrative appeal and deciding that the due process claim was 11 properly brought in a petition for writ of certiorari and that the due process claim was 12 ripe for review on the basis that the agency’s action was sufficiently final, given that, 13 otherwise, the plaintiff would be denied judicial review); Manning v. Mining & 14 Minerals Div., 2006-NMSC-027, ¶ 54 , 140 N.M. 528 , 144 P.3d 87

2013See, 8 e.g., Mills v. New Mexico State Bd. of Psychologist Exam’rs, 1997-NMSC-028 , ¶¶ 10- 9 11, 123 N.M. 421 , 941 P.2d 502 (discussing the two-pronged jurisdictional question 10 presented about the administrative appeal and deciding that the due process claim was 11 properly brought in a petition for writ of certiorari and that the due process claim was 12 ripe for review on the basis that the agency’s action was sufficiently final, given that, 13 otherwise, the plaintiff would be denied judicial review); Manning v. Mining & 14 Minerals Div., 2006-NMSC-027, ¶ 54 , 140 N.M. 528 , 144 P.3d 87

12013–2013
Celaya v. Hall green
nm · 2004
2 sentences

2007We agree. {20} "Liability of public employees acting within their scope of duty is governed by the TCA." Celaya v. Hall, 2004-NMSC-005, ¶ 8 , 135 N.M. 115 , 85 P.3d 239 .

2007We agree. {20} "Liability of public employees acting within their scope of duty is governed by the TCA." Celaya v. Hall, 2004-NMSC-005, ¶ 8 , 135 N.M. 115 , 85 P.3d 239 .

12007–2007
Califano v. Sanders green
scotus · 1977
2 sentences

2003State Corp. Comm’n, 1998-NMSC-032, ¶ 8 , 125 N.M. 798 , 965 P.2d 917 (quoting Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507 , 18 L.Ed.2d 681 (1967) {abrogated on other grounds by Califano v. Sanders, 430 U.S. 99, 105 , 97 S.Ct. 980 , 51 L.Ed.2d 192 (1977))).

2003State Corp. Comm’n, 1998-NMSC-032, ¶ 8 , 125 N.M. 798 , 965 P.2d 917 (quoting Abbott Labs. v. Gardner, 387 U.S. 136, 148 , 87 S.Ct. 1507 , 18 L.Ed.2d 681 (1967) {abrogated on other grounds by Califano v. Sanders, 430 U.S. 99, 105 , 97 S.Ct. 980 , 51 L.Ed.2d 192 (1977))).

12003–2003

Statutes the citing opinions construe

NM § N.M. Stat. § 44-6-1 (9) NM § N.M. Stat. § 44-6-2 (7) NM § N.M. Stat. § 44-6-4 (4) NM § N.M. Stat. § 10-7E-1 (3) NM § N.M. Stat. § 10-7E-26 (3) NM § N.M. Stat. § 30-18-1 (3) NM § N.M. Stat. § 34-5-14 (3) NM § N.M. Stat. § 44-2-4 (3) NM § N.M. Stat. § 44-2-6 (3) NM § N.M. Stat. § 53-8-17 (3) NM § N.M. Stat. § 53-8-25 (3) NM § N.M. Stat. § 62-6-4 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 218 (1991–2026) CA 127 (1985–2026) OH 76 (1998–2025) CT 50 (1989–2026) IL 50 (1976–2026) PA 40 (1994–2023) MI 26 (1990–2026) WA 25 (1987–2026) IA 24 (1996–2026) NM 22 (1991–2022) ID 22 (2002–2024) DE 21 (1989–2026) TN 18 (1999–2026) KY 14 (1995–2024) UT 14 (1999–2025) AZ 13 (1984–2025) OR 13 (1993–2019) MD 12 (1996–2023) WY 12 (1983–2017) MT 12 (2001–2024) AK 11 (1989–2023) ME 11 (1982–2022) NY 11 (1986–2025) MO 9 (1989–2021) IN 9 (2000–2024) NH 9 (1998–2024) HI 8 (2001–2025) FL 8 (1995–2025) NJ 7 (1996–2026) WI 7 (1994–2021) DC 6 (1981–2008) AL 6 (2008–2025) CO 6 (2003–2010) LA 6 (1995–2013) NE 5 (1994–2020) VI 5 (2002–2014) MA 4 (1994–2021) KS 4 (2008–2015) MS 2 (2015–2015) MN 2 (2016–2023) RI 2 (2000–2008) NC 2 (1993–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check