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9 New Mexico opinions name it 2 courts 2007–2025 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.
| Case | Followed | Cited |
|---|---|---|
NEW ENERGY ECONOMY, INC. v. Shoobridgegreen2 sentences2025Our Supreme Court has 9 cautioned 10 against using a declaratory judgment action to challenge or review 11 administrative actions if such an approach would foreclose any 12 necessary fact-finding by the administrative entity, discourage reliance 13 on any special expertise that may exist at the administrative level, 14 disregard an exclusive statutory scheme for the review of 15 administrative decisions, or circumvent procedural or substantive 16 limitations that would otherwise limit review through means other than 17 a declaratory judgment action. 18 Shoobridge, 2010-NMSC-049, ¶ 10 (internal 2017See also New Energy Econ., 2010-NMSC-049 , 4 ¶ 12 (“[W]hen the matter at issue (1) is purely legal, (2) requires no specialized 5 agency fact-finding, and (3) there is no exclusive statutory remedy, it is a proper 6 matter for a declaratory judgment action and does not require exhaustion of 7 administrative remedies.”). 8 B. | 2 | 2 |
Grand Lodge of Ancient & Accepted Masons v. Taxation & Revenue Departmentgreen2 sentences2008Id. 2008Id. | 1 | 3 |
Zamora v. Village of Ruidoso Downsgreen2 sentences2007See Grand Lodge of Masons v. Taxation & Revenue Dep’t, 106 N.M. 179, 180-83 , 740 P.2d 1163, 1164-67 (Ct.App.1987) (declining to permit judicial review of property tax decision by declaratory judgment because the administrative decision was factually based and review “by declaratory judgment would eliminate the administrative record or substitute and avoid the standard of review the legislature has provided”); cf. Zamora v. Vill. of Ruidoso Downs, 120 N.M. 778, 781-83 , 907 P.2d 182, 185-87 (1995) (holding that a writ of certiorari was the only mode of review to determine whether the city’s te 2007See Grand Lodge of Masons v. Taxation & Revenue Dep’t, 106 N.M. 179, 180-83 , 740 P.2d 1163, 1164-67 (Ct.App.1987) (declining to permit judicial review of property tax decision by declaratory judgment because the administrative decision was factually based and review “by declaratory judgment would eliminate the administrative record or substitute and avoid the standard of review the legislature has provided”); cf. Zamora v. Vill. of Ruidoso Downs, 120 N.M. 778, 781-83 , 907 P.2d 182, 185-87 (1995) (holding that a writ of certiorari was the only mode of review to determine whether the city’s te | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New Mexico. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Smith v. City of Santa Fe
green
2 sentences2022In Smith v. City of Santa Fe, 2007-NMSC-055, ¶ 15 , 142 N.M. 786 , 171 P.3d 300 , we “caution[ed] against using a declaratory judgment action to challenge or review administrative actions if such an approach would . . . disregard an exclusive statutory scheme for the review of administrative decisions.” See also State ex rel. 2022In Smith v. City of Santa Fe, 2007-NMSC-055, ¶ 15 , 142 N.M. 786 , 171 P.3d 300 , we “caution[ed] against using a declaratory judgment action to challenge or review administrative actions if such an approach would . . . disregard an exclusive statutory scheme for the review of administrative decisions.” See also State ex rel. | 4 | 2010–2022 |
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.
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.