N.M. Stat. » N.M. Stat. / Chapter 28 / Article 22
New Mexico Statutes

N.M. Stat. § 28-22-2 (2026)

Definitions.

✓ current as of May 2026
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As used in the New Mexico Religious Freedom Restoration Act:

  A. "free exercise of religion" means an act or a refusal to act that is substantially
motivated by religious belief; and

    B. "government agency" means the state or any of its political subdivisions,
institutions, departments, agencies, commissions, committees, boards, councils,
bureaus or authorities.

History: Laws 2000 (2nd S.S.), ch. 17, § 2.

                                     ANNOTATIONS

Effective dates. — Laws 2000 (2nd S.S.), ch. 17 contained no effective date provision,
but, pursuant to N.M. Const., art. IV, § 23, was effective July 3, 2000, 90 days after the
adjournment of the legislature.
Notes of Decisions
Cited in 9 cases (2 in the last 5 years), 2012–2025 · leading case: Elane Photography, LLC v. Willock, 2013 NMSC 040 (N.M. 2013).
Sort: Relevance Newest Treatment
Elane Photography, LLC v. Willock, 2013 NMSC 040 (N.M. 2013). · cites it 16× “” Section 28-22-2(A). {73} Willock argues, and the Court of Appeals held, that the NMRFRA did not protect Elane Photography’s refusal to photograph Willock’s wedding, even though the refusal was religiously motivated, because the NMRFRA “was not meant to apply in suits between…”
State v. Bent, 2013 NMCA 108 (N.M. Ct. App. 2013). · cites it 2× “]” NMSA 1978, § 28-22-2(A) (2000). On appeal, neither party relies on New Mexico cases interpreting RFRA.”
Elane Photography, LLC v. Willock, 2012 NMCA 086 (N.M. Ct. App. 2012). · cites it 3× “” Section 28-22-2(B). {46} The text of the NMRFRA is clear in limiting its scope to cases in which a “government agency” has restricted aperson’s free exercise of religion.”
Elane Photography, LLC v. Willock, 2013 NMSC 40 (N.M. 2013). · cites it 8× “” Section 28-22-2(A). {73} Willock argues, and the Court of Appeals held, that the NMRFRA did not protect Elane Photography’s refusal to photograph Willock’s wedding, even though the refusal was religiously motivated, because the NMRFRA “was not meant to apply in suits between…”
Elane Photography, LLC v. Willock, 2012 NMCA 86 (N.M. Ct. App. 2012). · cites it 3× “” Section 28-22-2(B). {46} The text of the NMRFRA is clear in limiting its scope to cases in which a “government agency” has restricted a person’s free exercise of religion.”
State v. Bent (N.M. Ct. App. 2013). · cites it 2× “]” NMSA 1978, § 28-22-2(A) (2000). On appeal, neither party relies on New Mexico cases interpreting RFRA.”
Unknown, 599 F.3d 1114. “” N.M. Stat. § 28-22-2 (2004). Although there is some evidence in the record the decedent may have held beliefs that would have been violated by the autopsy, in this case the decedent did not “act” or “refus[e] to act” before his death.”
Young v. Shipman (D.N.M. 2024). “§ 28-22-2(B). Based on this difference, and citing Elane Photography, LLC v.”
Tomlin v. State of New Mexico (D.N.M. 2025). “A § 28-22-2. See Elane Photography, LLC v. Willock, 2013- NMSC-040, 309 P.”
— N.M. Stat. § 28-22-2(A) — 4 cases
Elane Photography, LLC v. Willock, 2013 NMSC 040 (N.M. 2013). “” Section 28-22-2(A). {73} Willock argues, and the Court of Appeals held, that the NMRFRA did not protect Elane Photography’s refusal to photograph Willock’s wedding, even though the refusal was religiously motivated, because the NMRFRA “was not meant to apply in suits between…”
State v. Bent, 2013 NMCA 108 (N.M. Ct. App. 2013). “]” NMSA 1978, § 28-22-2(A) (2000). On appeal, neither party relies on New Mexico cases interpreting RFRA.”
Elane Photography, LLC v. Willock, 2013 NMSC 40 (N.M. 2013). “” Section 28-22-2(A). {73} Willock argues, and the Court of Appeals held, that the NMRFRA did not protect Elane Photography’s refusal to photograph Willock’s wedding, even though the refusal was religiously motivated, because the NMRFRA “was not meant to apply in suits between…”
State v. Bent (N.M. Ct. App. 2013). “]” NMSA 1978, § 28-22-2(A) (2000). On appeal, neither party relies on New Mexico cases interpreting RFRA.”
— N.M. Stat. § 28-22-2(B) — 5 cases
Elane Photography, LLC v. Willock, 2013 NMSC 040 (N.M. 2013). “” Section 28-22-2(A). {73} Willock argues, and the Court of Appeals held, that the NMRFRA did not protect Elane Photography’s refusal to photograph Willock’s wedding, even though the refusal was religiously motivated, because the NMRFRA “was not meant to apply in suits between…”
Elane Photography, LLC v. Willock, 2012 NMCA 086 (N.M. Ct. App. 2012). “” Section 28-22-2(B). {46} The text of the NMRFRA is clear in limiting its scope to cases in which a “government agency” has restricted aperson’s free exercise of religion.”
Elane Photography, LLC v. Willock, 2013 NMSC 40 (N.M. 2013). “” Section 28-22-2(A). {73} Willock argues, and the Court of Appeals held, that the NMRFRA did not protect Elane Photography’s refusal to photograph Willock’s wedding, even though the refusal was religiously motivated, because the NMRFRA “was not meant to apply in suits between…”
Elane Photography, LLC v. Willock, 2012 NMCA 86 (N.M. Ct. App. 2012). “” Section 28-22-2(B). {46} The text of the NMRFRA is clear in limiting its scope to cases in which a “government agency” has restricted a person’s free exercise of religion.”
Young v. Shipman (D.N.M. 2024). “§ 28-22-2(B). Based on this difference, and citing Elane Photography, LLC v.”
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