N.M. Stat. » N.M. Stat. / Chapter 12 / Article 2A
New Mexico Statutes

N.M. Stat. § 12-2A-13 (2026)

Headings and titles.

✓ current as of May 2026
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Headings and titles may not be used in construing a statute or rule unless they are
contained in the enrolled and engrossed bill or rule as adopted.

History: Laws 1997, ch. 173, § 13.

                                      ANNOTATIONS

Effective dates. — Laws 1997, ch. 173 § 22 made the Uniform Statute and Rule
Construction Act effective July 1, 1997.

Legislative intent. — While a statutory heading cannot be used to produce ambiguity
in a statute that is otherwise clearly drafted, a legislatively drafted section heading may
be useful in determining legislative intent. Serrano v. State, Dep't of Alcoholic Beverage
Control, 1992-NMCA-015, 113 N.M. 444, 827 P.2d 159.

Headings not law. — The headings on each section of the statutes appearing in the
1953 statutes annotated are not part of the law. They were added by the editors and are
merely descriptive and intended as aids in the use of the statutes. City of Albuquerque
v. Campbell, 1960-NMSC-138, 68 N.M. 75, 358 P.2d 698.

Title of statute may be referred to for resolving doubts concerning statute's
meaning. State ex rel. Sedillo v. Sargent, 1918-NMSC-042, 24 N.M. 333, 171 P. 790.
Notes of Decisions
Cited in 12 cases (3 in the last 5 years), 2010–2025 · leading case: Chatterjee v. King, 2011 NMCA 12 (N.M. Ct. App. 2010).
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Chatterjee v. King, 2011 NMCA 12 (N.M. Ct. App. 2010). · cites it 6× “See NMSA 1978, § 12-2A-13 (1997) (“Headings and titles may not be used in construing a statute or rule unless they are contained in the enrolled and engrossed bill or rule as adopted.”
Nash v. Bd. of Cnty. Comm'rs of Catron Cnty. & Belen Consol. Sch. Dist. v. Valencia Cnty., 2021 NMSC 005 (N.M. 2020). · cites it 2× “See NMSA 1978, § 12-2A-13 (1997) (“Headings and titles may not be used in construing a statute or rule unless they are contained in the enrolled and engrossed bill or rule as adopted.”
Tri-State Generation & Transmission. Ass'n. v. D'Antonio, 2012 NMSC 39 (N.M. 2012). · cites it 2× “” NMSA 1978, § 12-2A-13 (1997); see Black’s Law Dictionary 186 (9th ed.”
State v. Gutierrez, 523 P.3d 560 (N.M. 2022). · cites it 2× “NMSA 1978, § 12-2A-13 (1997) (“Headings and titles may not be used in construing a statute or rule unless they are contained in the enrolled and engrossed bill or rule as adopted.”
State v. Gutierrez, 2020 NMCA 045 (N.M. Ct. App. 2020). · cites it 2× “{15} Initially we note that when discerning the Legislature’s intent, we may look to a section’s heading, “and ordinarily it may be considered as a part of the act if necessary to its construction.”
State v. Ho, 2014 NMCA 38 (N.M. Ct. App. 2014). · cites it 2× “¶¶ 14-16 (using the titles to analyze the amendments to the DWI statute and determining that each bill addressed a different purpose); see also NMSA 1978, § 12-2A-13 (1997) (“Headings and titles may .”
State v. Trung Ho, 2014 NMCA 038 (N.M. Ct. App. 2014). · cites it 2× “¶¶ 14-16 (using the titles to analyze the amendments to the DWI statute and determining that each bill addressed a different purpose); see also NMSA 1978, § 12-2A-13 (1997) (“Headings and titles may .”
Chatterjee v. King, 253 P.3d 915 (N.M. Ct. App. 2011). · cites it 3× “See NMSA 1978, § 12-2A-13 (1997) ("Headings and titles may not be used in construing a statute or rule unless they are contained in the enrolled and engrossed bill or rule as adopted.”
State v. Gutierrez (N.M. 2022). · cites it 2× “NMSA 1978, § 12-2A-13 (1997) (“Headings and titles may not be used in construing a statute or rule unless they are contained in the enrolled and engrossed bill or rule as adopted.”
Golden Servs. v. N.M. Taxation & Revenue Dep't (N.M. Ct. App. 2020). · cites it 2× “While also not dispositive of legislative intent, the title may aid in construing a statute to resolve existing doubts or ambiguities as to the statutory meanings if the title is in the enrolled and engrossed bill.”
Lerma v. State (N.M. 2025). · cites it 2× “NMSA 1978, § 12-2A-13 (1997); see Black’s Law Dictionary 186 (9th ed.”
State v. Ho (N.M. Ct. App. 2014). · cites it 2× “¶¶ 14-16 (using the titles to analyze the amendments to the DWI statute and determining that each bill addressed a different purpose); see also NMSA 1978, § 12-2A-13 (1997) (“Headings and titles may .”
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