takings claim (New Mexico) · Go Syfert
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takings claim in New Mexico

16 New Mexico opinions name it 2 courts 1995–2026 2 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 (6)

CaseFollowedCited
Dlx, Inc. v. Commonwealth of Kentuckygreen
ca6 · 2004 · cited in 2 New Mexico opinions naming this issue, 2006–2006
2 sentences

2006In addressing a takings claim against the State of Kentucky in federal court, the Sixth Circuit noted that, notwithstanding constitutional sovereign immunity, the “Fifth Amendment’s requirement of just compensation forces the states to provide a judicial remedy in their own courts.” DLX, Inc. v. Kentucky, 381 F.3d 511, 527 (6th Cir.2004).

2006In addressing a takings claim against the State of Kentucky in federal court, the Sixth Circuit noted that, notwithstanding constitutional sovereign immunity, the "Fifth Amendment's requirement of just compensation forces the states to provide a judicial remedy in their own courts." DLX, Inc. v. Kentucky, 381 F.3d 511, 527 (6th Cir.2004).

22
State Ex Rel. State Highway Commission v. Mauneygreen
nm · 1966 · cited in 1 New Mexico opinions naming this issue, 2026–2026
2 sentences

2026State Highway Comm’n v. 18 Mauney, 1966-NMSC-035 , ¶¶ 1, 7-9, 18-19, 24, 76 N.M. 36 , 411 P.2d 1009 19 (rejecting a takings claim that was based on diminished traffic passing a landowner’s 1 business and changed the access route to the property, because the road project did 2 not cause total deprivation of access). 3 {16} In the present case the regulations do not require elk to be on private property 4 or deny a property owner the right to exclude them—the regulations only limit how 5 a property owner can hunt, harm, or remove them.

2026State Highway Comm’n v. 18 Mauney, 1966-NMSC-035 , ¶¶ 1, 7-9, 18-19, 24, 76 N.M. 36 , 411 P.2d 1009 19 (rejecting a takings claim that was based on diminished traffic passing a landowner’s 1 business and changed the access route to the property, because the road project did 2 not cause total deprivation of access). 3 {16} In the present case the regulations do not require elk to be on private property 4 or deny a property owner the right to exclude them—the regulations only limit how 5 a property owner can hunt, harm, or remove them.

11
Calvary Chapel Dayton Valley v. Sisolakgreen
· 2020 · cited in 1 New Mexico opinions naming this issue, 2021–2021
1 sentence

2021The Real Parties cite Calvary Chapel Dayton Valley v. Sisolak, 140 S. Ct. 2603, 2605 (2020) (mem.) (Alito, J., dissenting), for the proposition that “as States have time to craft policies in light of [increasing medical and scientific] evidence, courts should expect policies that more carefully account for constitutional rights.” Petitioners argue that valid exercises of the police power to protect the public health cannot support a takings claim and that Penn Central is inapposite.

11
Santa Fe Pacific Trust, Inc. v. City of Albuquerquegreen
nmctapp · 2014 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020See SFPT, 2014-NMCA-093 , ¶ 21.

11
Bustamante v. City of Las Crucesgreen
nmctapp · 1992 · cited in 1 New Mexico opinions naming this issue, 2008–2008
2 sentences

2008See Bustamante v. City of Las Cruces, 114 N.M. 179, 182 , 836 P.2d 98, 101 (Ct.App.1992) (“[T]his court will affirm a lower court’s decision that reaches the correct result for the wrong reason.”).

2008See Bustamante v. City of Las Cruces, 114 N.M. 179, 182 , 836 P.2d 98, 101 (Ct.App.1992) (“[T]his court will affirm a lower court’s decision that reaches the correct result for the wrong reason.”).

11
Hyde Park Co. v. Santa Fe City Councilgreen
ca10 · 2000 · cited in 1 New Mexico opinions naming this issue, 2001–2001
1 sentence

2001See Hyde Park Co. v. Santa Fe City Council, 226 F.3d 1207, 1210 (10th Cir. 2000) (stating that an “abstract need for, or unilateral expectation of,” some benefits does not constitute “ ‘property [interests]’ ” of the type protected by the due process clause); see also State ex rel.

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 (13)

CaseCitedYears
Agins v. City of Tiburon red
scotus · 1980
2 sentences

2014In doing so, the court relied in part on Agins, in which the United States Supreme Court stated that a city’s pre-condemnation activities did not “so burden[] the appellants’ enjoyment of their property as to constitute a taking.” 447 U.S. at 263 n.9.

2014In doing so, the court relied in part on Agins, in which the United States Supreme Court stated that a city’s pre-condemnation activities did not “so burden}] the appellants’ enjoyment of their property as to constitute a taking.” 447 U.S. at 263 n.9.

32014–2014
Aronson v. Quick Point Pencil Co. green
scotus · 1979
2 sentences

2011Aronson v. Quick Point Pencil Co., 440 U.S. 257, 262 , 99 S.Ct. 1096 , 59 L.Ed.2d 296 (1979) (internal quotation marks and citation omitted).

2011Aronson v. Quick Point Pencil Co., 440 U.S. 257, 262 , 99 S.Ct. 1096 , 59 L.Ed.2d 296 (1979) (internal quotation marks and citation omitted).

22011–2011
Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional Planning Agency green
scotus · 2002
2 sentences

2006Palazzolo, 533 U.S. at 632 , 121 S.Ct. 2448 . {15} Most recently, in Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional Planning Agency, 535 U.S. 302, 306-09 , 122 S.Ct. 1465 , 152 L.Ed.2d 517 (2002), the takings claim was brought against an interstate regional planning agency, created by legislation in both California and Nevada, and comprised of individuals from both states.

2006Palazzolo, 533 U.S. at 632 , 121 S.Ct. 2448 . {15} Most recently, in Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional Planning Agency, 535 U.S. 302, 306-09 , 122 S.Ct. 1465 , 152 L.Ed.2d 517 (2002), the takings claim was brought against an interstate regional planning agency, created by legislation in both California and Nevada, and comprised of individuals from both states.

22006–2006
Palazzolo v. Rhode Island green
scotus · 2001
2 sentences

2006Palazzolo, 533 U.S. at 632 , 121 S.Ct. 2448 . {15} Most recently, in Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional Planning Agency, 535 U.S. 302, 306-09 , 122 S.Ct. 1465 , 152 L.Ed.2d 517 (2002), the takings claim was brought against an interstate regional planning agency, created by legislation in both California and Nevada, and comprised of individuals from both states.

2006Palazzolo, 533 U.S. at 632 , 121 S.Ct. 2448 . {15} Most recently, in Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional Planning Agency, 535 U.S. 302, 306-09 , 122 S.Ct. 1465 , 152 L.Ed.2d 517 (2002), the takings claim was brought against an interstate regional planning agency, created by legislation in both California and Nevada, and comprised of individuals from both states.

22006–2006
Mugler v. Kansas green
· 1887
1 sentence

2021The Real Parties’ arguments fail for two reasons. {47} First, as discussed above,20 a reasonable use regulation under the police power to prevent injury to the health of the community “‘cannot . . . be deemed a taking.’” Keystone, 480 U.S. at 489 (quoting Mugler, 123 U.S. at 668-69 ).

12021–2021
Keystone Bituminous Coal Assn. v. DeBenedictis green
scotus · 1987
1 sentence

2021The Real Parties’ arguments fail for two reasons. {47} First, as discussed above,20 a reasonable use regulation under the police power to prevent injury to the health of the community “‘cannot . . . be deemed a taking.’” Keystone, 480 U.S. at 489 (quoting Mugler, 123 U.S. at 668-69 ).

12021–2021
State Ex Rel. Helman v. Gallegos green
nm · 1994
1 sentence

2020Helman v. Gallegos, 1994-NMSC-023 , ¶ 20, 117 N.M. 6By contrast, Amicus Anaheim Jacks and Papa’s Pawn Amici argue that this Court should reach the takings claim under Section 12-10A-15(A). 346, 871 P.2d 1352 (internal quotation marks and citation omitted).

12020–2020
State v. Davis green
nm · 2003
2 sentences

2020Thus, where statutory language is “doubtful, ambiguous, or an adherence to the literal use of the words would lead to injustice, absurdity or contradiction,” we construe a statute “according to its obvious spirit or reason.” State v. Davis, 2003-NMSC-022, ¶ 6 , 134 N.M. 172 , 74 P.3d 1064 ; Bd. of Educ. for the Carlsbad Mun.

2020Thus, where statutory language is “doubtful, ambiguous, or an adherence to the literal use of the words would lead to injustice, absurdity or contradiction,” we construe a statute “according to its obvious spirit or reason.” State v. Davis, 2003-NMSC-022, ¶ 6 , 134 N.M. 172 , 74 P.3d 1064 ; Bd. of Educ. for the Carlsbad Mun.

12020–2020
ALBUQUERQUE COMMONS v. City Council green
nmctapp · 2006
2 sentences

2008Commons II, 2006-NMCA-143, ¶ 29 , 140 N.M. 751 , 149 P.3d 67 .

2008The Court of Appeals then stated that the effect of its opinion was “to uphold the City’s denial of the site plan under the [1981 Uptown Sector Plan].” Commons II, 2006-NMCA-143, ¶ 87 , 140 N.M. 751 , 149 P.3d 67 .

12008–2008
Albuquerque Commons Partnership v. City Council of Albuquerque green
nmctapp · 2006
2 sentences

2008Commons II, 2006-NMCA-143, ¶ 29 , 140 N.M. 751 , 149 P.3d 67 .

2008Commons II, 2006-NMCA-143, ¶ 29 , 140 N.M. 751 , 149 P.3d 67 .

12008–2008
Walker v. United States green
uscfc · 2005
1 sentence

2007Id. at 62 . {6} In examining the Walkers’ takings claim, the Court of Claims concluded that New Mexico state law determines the nature of any alleged property interests taken by the federal government.

12007–2007
Walker v. United States green
uscfc · 2005
1 sentence

2007Walker II, 69 Fed.

12007–2007
United States v. North American Transportation & Trading Co. green
scotus · 1920
2 sentences

1995Citing for support United States v. North American Transportation & Trading Co., 253 U.S. 330, 333-34 , 40 S.Ct. 518, 519-20 , 64 L.Ed. 935 (1920), the County argues that “[ajction without statutory authority is not governmental action and therefore cannot constitute [a claim for] inverse condemnation or a taking.” Although North American Transportation arguably supports that proposition, we need not address this argument because of our holding that to support a takings claim, a property owner must prove a deprivation of all or substantially all beneficial use of the subject property. 14.

1995Citing for support United States v. North American Transportation & Trading Co., 253 U.S. 330, 333-34 , 40 S.Ct. 518, 519-20 , 64 L.Ed. 935 (1920), the County argues that “[ajction without statutory authority is not governmental action and therefore cannot constitute [a claim for] inverse condemnation or a taking.” Although North American Transportation arguably supports that proposition, we need not address this argument because of our holding that to support a takings claim, a property owner must prove a deprivation of all or substantially all beneficial use of the subject property. 14.

11995–1995

Statutes the citing opinions construe

NM § N.M. Stat. § 42A-1-29 (7) USC § 42u.s.c.1983 (6)

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 409 (1993–2026) CA 136 (1982–2026) WA 73 (1984–2026) IL 47 (1991–2025) OH 42 (1992–2026) CT 41 (1988–2023) MI 35 (1989–2026) FL 35 (1992–2026) PA 32 (1992–2026) NY 29 (1987–2026) OR 27 (1992–2024) MA 26 (1988–2025) UT 22 (1990–2020) CO 20 (1993–2025) MN 18 (1990–2025) SC 18 (1991–2023) GA 17 (1994–2025) MD 17 (1989–2024) IA 17 (1993–2023) RI 17 (1996–2026) NJ 17 (1991–2025) NM 16 (1995–2026) WI 14 (1995–2026) ID 14 (2003–2022) NC 13 (1989–2026) VT 13 (1994–2025) LA 12 (1994–2026) AK 11 (1987–2025) HI 11 (1995–2025) ME 11 (1982–2025) NV 10 (2007–2024) DC 10 (1998–2024) MO 10 (1990–2021) MT 10 (2001–2022) AZ 10 (1995–2024) NH 9 (2000–2023) ND 8 (2005–2024) IN 7 (1993–2026) NE 7 (2000–2022) SD 6 (2002–2024) MS 6 (2002–2026) VA 5 (2001–2017) KS 4 (1996–2012) WV 4 (2003–2020) DE 3 (2016–2022) AR 2 (1999–2025) WY 2 (2017–2017) OK 2 (2004–2025)

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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