ipra exception (New Mexico) · Go Syfert
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ipra exception in New Mexico

19 New Mexico opinions name it 2 courts 2006–2026 9 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 (7)

CaseFollowedCited
Britton v. Office of the Att'y Gen.green
nmctapp · 2018 · cited in 4 New Mexico opinions naming this issue, 2019–2024
2 sentences

2024While statutory silence may often 3 permit us to infer legislative intent, we cannot, and will not, interpret IPRA in a 4 manner that undermines its expressly stated and strongly reiterated public policy. 5 See Britton, 2019-NMCA-002, ¶ 29 (“The starting point for any court tasked with 6 resolving an IPRA challenge is to place into statutory context the particular 7 arguments made vis-à-vis the Legislature’s declared purpose in enacting IPRA.”). 8 {55} Defendants, therefore, improperly denied the Journal’s request at the time of 9 their response stating that they did not have any responsive do

2024While statutory silence may often 3 permit us to infer legislative intent, we cannot, and will not, interpret IPRA in a 4 manner that undermines its expressly stated and strongly reiterated public policy. 5 See Britton, 2019-NMCA-002, ¶ 29 (“The starting point for any court tasked with 6 resolving an IPRA challenge is to place into statutory context the particular 7 arguments made vis-à-vis the Legislature’s declared purpose in enacting IPRA.”). 8 {55} Defendants, therefore, improperly denied the Journal’s request at the time of 9 their response stating that they did not have any responsive do

34
Republican Party v. New Mexico Taxation & Revenue Departmentgreen
nm · 2012 · cited in 2 New Mexico opinions naming this issue, 2020–2024
2 sentences

2024Republican Party of N.M., 2012-NMSC-026, ¶ 13 (internal quotation marks and citation omitted); see id. ¶ 16 (stating that courts analyzing an IPRA claim must “restrict their analysis to whether disclosure under IPRA may be withheld because of a specific exception contained within IPRA, or statutory or regulatory exceptions”). {8} The Corrections Department Act allows the Secretary of Corrections (the Secretary) to “make and adopt such reasonable and procedural rules and regulations as may be necessary to carry out the duties of the department and its divisions.” Section 9- 3-5(E).

2024Republican Party of N.M., 2012-NMSC-026, ¶ 13 (internal quotation marks and citation omitted); see id. ¶ 16 (stating that courts analyzing an IPRA claim must “restrict their analysis to whether disclosure under IPRA may be withheld because of a specific exception contained within IPRA, or statutory or regulatory exceptions”). {8} The Corrections Department Act allows the Secretary of Corrections (the Secretary) to “make and adopt such reasonable and procedural rules and regulations as may be necessary to carry out the duties of the department and its divisions.” Section 9- 3-5(E).

22
Faber v. Kinggreen
nmctapp · 2013 · cited in 2 New Mexico opinions naming this issue, 2015–2015
2 sentences

2015See generally Faber v. King, 2013-NMCA-080 , 306 P.3d 519 .

2015See generally Faber v. King, 2013-NMCA-080 , 306 P.3d 519 .

22
ACLU of New Mexico v. Durangreen
nmctapp · 2016 · cited in 4 New Mexico opinions naming this issue, 2018–2022
2 sentences

2022“Our IPRA jurisprudence contemplates in camera review in circumstances in which the applicability of a disclosure exception is in question.” Duran, 2016-NMCA-063 , ¶ 45.

2019See ACLU of N.M., 2016-NMCA-063, ¶ 27 (discussing how liability for failure to produce a public record in response to an IPRA request hinges on whether the public record was identified with reasonable particularity within the request). {47} Based on the record before us, the only public records produced after the district court’s later reversed dismissal of Plaintiff’s enforcement complaint that may serve as a basis for an IPRA violation and warrant an award of costs and attorney fees are the documents KNME and UNM made available for inspection in October 2013.

14
Jones v. N.M. Dep't of Public Safetygreen
nm · 2020 · cited in 1 New Mexico opinions naming this issue, 2026–2026
2 sentences

2026Toomey v. City of Truth or Consequences, 2012-NMCA-104 , 7 ¶ 22, 287 P.3d 364 (“We emphasize . . . that IPRA should be construed broadly to 8 effectuate its purposes, and courts should avoid narrow definitions that would defeat 9 the intent of the Legislature.”); Jones, 2020-NMSC-013, ¶¶ 38, 40 (reversing the 10 district court’s interpretation of an IPRA exception that was “untethered from the 11 plain language of [the exception] and overbroad”). 12 {23} Looking to whether the Padilla Report may contain information that is exempt 13 under the text and purpose of Section 14-2-1(C), we note that

2026Toomey v. City of Truth or Consequences, 2012-NMCA-104 , 7 ¶ 22, 287 P.3d 364 (“We emphasize . . . that IPRA should be construed broadly to 8 effectuate its purposes, and courts should avoid narrow definitions that would defeat 9 the intent of the Legislature.”); Jones, 2020-NMSC-013, ¶¶ 38, 40 (reversing the 10 district court’s interpretation of an IPRA exception that was “untethered from the 11 plain language of [the exception] and overbroad”). 12 {23} Looking to whether the Padilla Report may contain information that is exempt 13 under the text and purpose of Section 14-2-1(C), we note that

11
Matter of Adoption of Doegreen
nm · 1984 · cited in 1 New Mexico opinions naming this issue, 2022–2022
2 sentences

2022See In re Adoption of Doe, 1984-NMSC-024 , ¶ 2, 100 N.M. 764 , 676 P.2d 1329 (holding that issues “unsupported by cited authority will not be reviewed by us on appeal”). [CN 2] In his memorandum in opposition to that disposition, Petitioner continues to cite no authority for this proposition, and instead merely suggests that it was unreasonable to send a CD without a cover letter.

2022See In re Adoption of Doe, 1984-NMSC-024 , ¶ 2, 100 N.M. 764 , 676 P.2d 1329 (holding that issues “unsupported by cited authority will not be reviewed by us on appeal”). [CN 2] In his memorandum in opposition to that disposition, Petitioner continues to cite no authority for this proposition, and instead merely suggests that it was unreasonable to send a CD without a cover letter.

11
Hennessy v. Duryeagreen
nmctapp · 1998 · cited in 1 New Mexico opinions naming this issue, 2017–2017
2 sentences

2017See 10 Hennessy v. Duryea, 1998-NMCA-036, ¶ 24 , 124 N.M. 754 , 955 P.2d 683 (“Our 11 courts have repeatedly held that, in summary calendar cases, the burden is on the party 12 opposing the proposed disposition to clearly point out errors in fact or law.”). 13 {6} Additionally, Plaintiff argues she is not required to file a brief to prove that she 14 has a right to sue the Proposed State Defendants, and also that no briefs have been 15 filed to establish (1) futility, (2) that there has not been a waiver of governmental 16 immunity, and (3) that the Proposed State Defendants did not violate th

2017See 10 Hennessy v. Duryea, 1998-NMCA-036, ¶ 24 , 124 N.M. 754 , 955 P.2d 683 (“Our 11 courts have repeatedly held that, in summary calendar cases, the burden is on the party 12 opposing the proposed disposition to clearly point out errors in fact or law.”). 13 {6} Additionally, Plaintiff argues she is not required to file a brief to prove that she 14 has a right to sue the Proposed State Defendants, and also that no briefs have been 15 filed to establish (1) futility, (2) that there has not been a waiver of governmental 16 immunity, and (3) that the Proposed State Defendants did not violate th

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 (11)

CaseCitedYears
Crutchfield v. New Mexico Department of Taxation & Revenue green
nmctapp · 2004
2 sentences

2023Dep’t of Tax’n & 7 Revenue, 2005-NMCA-022, ¶ 36 , 137 N.M. 26 , 106 P.3d 1273 (“A reviewing court 8 generally does not decide academic or moot questions.”). 9 CONCLUSION 10 {25} We reverse the district court’s determination that attorney-client privilege 11 exempts the January 7 email from inspection under IPRA, and remand this matter 12 for further proceedings consistent with this opinion.

2023Dep’t of Tax’n & 7 Revenue, 2005-NMCA-022, ¶ 36 , 137 N.M. 26 , 106 P.3d 1273 (“A reviewing court 8 generally does not decide academic or moot questions.”). 9 CONCLUSION 10 {25} We reverse the district court’s determination that attorney-client privilege 11 exempts the January 7 email from inspection under IPRA, and remand this matter 12 for further proceedings consistent with this opinion.

22023–2023
State ex rel. Toomey v. City of Truth or Consequences green
nmctapp · 2012
2 sentences

2026Toomey v. City of Truth or Consequences, 2012-NMCA-104 , 7 ¶ 22, 287 P.3d 364 (“We emphasize . . . that IPRA should be construed broadly to 8 effectuate its purposes, and courts should avoid narrow definitions that would defeat 9 the intent of the Legislature.”); Jones, 2020-NMSC-013, ¶¶ 38, 40 (reversing the 10 district court’s interpretation of an IPRA exception that was “untethered from the 11 plain language of [the exception] and overbroad”). 12 {23} Looking to whether the Padilla Report may contain information that is exempt 13 under the text and purpose of Section 14-2-1(C), we note that

2026Toomey v. City of Truth or Consequences, 2012-NMCA-104 , 7 ¶ 22, 287 P.3d 364 (“We emphasize . . . that IPRA should be construed broadly to 8 effectuate its purposes, and courts should avoid narrow definitions that would defeat 9 the intent of the Legislature.”); Jones, 2020-NMSC-013, ¶¶ 38, 40 (reversing the 10 district court’s interpretation of an IPRA exception that was “untethered from the 11 plain language of [the exception] and overbroad”). 12 {23} Looking to whether the Padilla Report may contain information that is exempt 13 under the text and purpose of Section 14-2-1(C), we note that

12026–2026
State v. Vest green
nm · 2021
2 sentences

2026We therefore “give 15 those words their ordinary meaning absent clear and express legislative intention to 16 the contrary.” State v Vest, 2021-NMSC-020 , ¶ 14, 488 P.3d 626 (text only) (citation 17 omitted).

2026We therefore “give 15 those words their ordinary meaning absent clear and express legislative intention to 16 the contrary.” State v Vest, 2021-NMSC-020 , ¶ 14, 488 P.3d 626 (text only) (citation 17 omitted).

12026–2026
Premier Trust of Nevada, Inc. v. City of Albuquerque green
nmctapp · 2020
2 sentences

2024Sheriff Gonzales Has Not Met His Burden to Reverse the District Court’s Decision to Dismiss His CRA Bill of Rights Claim or His IPRA Claim {8} In one paragraph in his briefing to this Court, Sheriff Gonzales argues that the district court erred in dismissing both his CRA Bill of Rights claim and his IPRA claim. “[I]t is the appellant’s burden to demonstrate, by providing well-supported and clear arguments, that the district court has erred.” Premier Tr. of Nev., Inc. v. City of Albuquerque, 2021-NMCA-004, ¶ 10 , 482 P.3d 1261 .

2024Sheriff Gonzales Has Not Met His Burden to Reverse the District Court’s Decision to Dismiss His CRA Bill of Rights Claim or His IPRA Claim {8} In one paragraph in his briefing to this Court, Sheriff Gonzales argues that the district court erred in dismissing both his CRA Bill of Rights claim and his IPRA claim. “[I]t is the appellant’s burden to demonstrate, by providing well-supported and clear arguments, that the district court has erred.” Premier Tr. of Nev., Inc. v. City of Albuquerque, 2021-NMCA-004, ¶ 10 , 482 P.3d 1261 .

12024–2024
Britton v. Office of the Attorney Gen. of N.M. green
nmctapp · 2018
2 sentences

2022Instead, citing Britton v. Office of Attorney General, 2019-NMCA-002 , 433 P.3d 320 , Plaintiff contends that Defendant waived the opportunity to assert that IPRA exception because it was not set forth in the initial response.

2022Instead, citing Britton v. Office of Attorney General, 2019-NMCA-002 , 433 P.3d 320 , Plaintiff contends that Defendant waived the opportunity to assert that IPRA exception because it was not set forth in the initial response.

12022–2022
Republican Party of N.M. v. New Mexico Taxation & Revenue Dep't green
nmctapp · 2010
2 sentences

2020Taxation & Revenue Dep’t, 2010-NMCA-080, ¶ 16 , 148 N.M. 877 , 242 P.3d 444 (involving no dispute that the New Mexico Motor Vehicle Division collected and kept public records containing drivers’ personal information related to issuing drivers’ licenses that would have been subject to disclosure provided there was no applicable exception; namely, the federal and state privacy acts that protect the private information related to drivers and list a number of exceptions that may apply to the redacted personal information), rev’d on other grounds, 2012-NMSC-026, ¶¶ 4, 11, 13 , 283 P.3d 853 (indicat

2020Taxation & Revenue Dep’t, 2010-NMCA-080, ¶ 16 , 148 N.M. 877 , 242 P.3d 444 (involving no dispute that the New Mexico Motor Vehicle Division collected and kept public records containing drivers’ personal information related to issuing drivers’ licenses that would have been subject to disclosure provided there was no applicable exception; namely, the federal and state privacy acts that protect the private information related to drivers and list a number of exceptions that may apply to the redacted personal information), rev’d on other grounds, 2012-NMSC-026, ¶¶ 4, 11, 13 , 283 P.3d 853 (indicat

12020–2020
Republican Party of NM v. NM TAXATION neutral
nmctapp · 2010
1 sentence

2020Taxation & Revenue Dep’t, 2010-NMCA-080, ¶ 16 , 148 N.M. 877 , 242 P.3d 444 (involving no dispute that the New Mexico Motor Vehicle Division collected and kept public records containing drivers’ personal information related to issuing drivers’ licenses that would have been subject to disclosure provided there was no applicable exception; namely, the federal and state privacy acts that protect the private information related to drivers and list a number of exceptions that may apply to the redacted personal information), rev’d on other grounds, 2012-NMSC-026, ¶¶ 4, 11, 13 , 283 P.3d 853 (indicat

12020–2020
Faber v. King green
nmctapp · 2015
1 sentence

2019Faber, 2015-NMSC-015, ¶ 17 .

12019–2019
Board of Education, Rio Rancho Public School District v. Johnson neutral
nmctapp · 1998
2 sentences

2018Cobb v. Gammon, 2017-NMCA-022 , ¶ 13, 389 P.3d 1058 (“An issue 2 is moot when no actual controversy exists, and the court cannot grant actual relief.”); 3 Bd. of Educ. v. Johnson, 1998-NMCA-048, ¶ 5 , 125 N.M. 91 , 957 P.2d 76 (“[A] party 4 waives her right to appeal when she accepts the benefits of a judgment.” (internal 5 quotation marks and citation omitted)).

2018Cobb v. Gammon, 2017-NMCA-022 , ¶ 13, 389 P.3d 1058 (“An issue 2 is moot when no actual controversy exists, and the court cannot grant actual relief.”); 3 Bd. of Educ. v. Johnson, 1998-NMCA-048, ¶ 5 , 125 N.M. 91 , 957 P.2d 76 (“[A] party 4 waives her right to appeal when she accepts the benefits of a judgment.” (internal 5 quotation marks and citation omitted)).

12018–2018
Farmers, Inc. v. Dal MacHine & Fabricating, Inc. green
nm · 1990
2 sentences

2017Additionally, we proposed to conclude that 3 1 Plaintiff had not demonstrated that the district court erred in denying her motion to 2 amend the complaint to add an IPRA claim. [CN 5] See Farmers, Inc. v. Dal Mach. 3 & Fabricating, Inc., 1990-NMSC-100 , ¶ 8, 111 N.M. 6 , 800 P.2d 1063 (stating that 4 the appellate courts presume that the district court is correct and the burden is on the 5 appellant to clearly demonstrate that the lower court erred). 6 {5} In her response, Plaintiff primarily reiterates the arguments she made in her 7 docketing statement and motion to reconsider. [See generall

2017Additionally, we proposed to conclude that 3 1 Plaintiff had not demonstrated that the district court erred in denying her motion to 2 amend the complaint to add an IPRA claim. [CN 5] See Farmers, Inc. v. Dal Mach. 3 & Fabricating, Inc., 1990-NMSC-100 , ¶ 8, 111 N.M. 6 , 800 P.2d 1063 (stating that 4 the appellate courts presume that the district court is correct and the burden is on the 5 appellant to clearly demonstrate that the lower court erred). 6 {5} In her response, Plaintiff primarily reiterates the arguments she made in her 7 docketing statement and motion to reconsider. [See generall

12017–2017
Southwest Community Health Services v. Smith green
nm · 1988
2 sentences

2006Although we will recognize limited immunity from discovery we will not “impinge upon the right of litigants to have their disputes decided on relevant and material evidence.” Southwest Cmty. Health Serv., 107 N.M. at 200 , 755 P.2d at 44 .

2006Although we will recognize limited immunity from discovery we will not “impinge upon the right of litigants to have their disputes decided on relevant and material evidence.” Southwest Cmty. Health Serv., 107 N.M. at 200 , 755 P.2d at 44 .

12006–2006

Statutes the citing opinions construe

NM § N.M. Stat. § 14-2-1 (19) NM § N.M. Stat. § 14-2-5 (11) NM § N.M. Stat. § 14-2-11 (10) NM § N.M. Stat. § 14-2-12 (9) NM § N.M. Stat. § 14-2-8 (8) NM § N.M. Stat. § 14-2-9 (7) NM § N.M. Stat. § 14-2-6 (6) NM § N.M. Stat. § 14-2-10 (4) NM § N.M. Stat. § 57-12-10 (4)

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

NM 19 (2006–2026) IL 3 (2020–2021)

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.

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