This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- The Plaintiff, a prisoner serving a life sentence, requested to inspect public records related to his murder conviction under the Inspection of Public Records Act (IPRA). He specified that the inspection should occur at the penitentiary and that he would request copies of specific pages after inspection. The Defendants responded with an invoice for the copies without providing an opportunity for physical inspection at the penitentiary, later stating that inspection could only occur at the Department of Public Safety (DPS) office during business hours (paras 2-3).
Procedural History
- District Court of Santa Fe County: Granted summary judgment in favor of Defendants and denied Plaintiff's motion to reconsider (para 1).
Parties' Submissions
- Plaintiff: Argued that Defendants failed to provide a proper and reasonable opportunity to inspect public records as required by IPRA, specifically that the records should be made available for inspection at the penitentiary (paras 2-3, 9).
- Defendants: Contended that they had provided reasonable access for physical inspection of public records by allowing inspection at the DPS offices and that IPRA does not require them to transport records to the requester's location (paras 3, 12).
Legal Issues
- Whether Defendants provided a proper and reasonable opportunity to inspect public records as required by the Inspection of Public Records Act (IPRA) (para 4).
Disposition
- The Court of Appeals reversed the district court's order granting summary judgment in favor of Defendants and remanded for further proceedings (para 14).
Reasons
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The Court, consisting of Judges Wray, Ives, and Yohalem, found that Defendants' response to Plaintiff's IPRA request was not reasonable under the circumstances. The Court determined that while the Defendants' first response (an invoice for copies) was proper under IPRA, their second response (stating inspection could only occur at the DPS office) was unreasonable given the Plaintiff's incarceration status. The Court emphasized that IPRA requires providing a proper and reasonable opportunity to inspect public records and that Defendants failed to consider all circumstances to fulfill this requirement. The decision to reverse and remand was based on the interpretation of IPRA's purpose to ensure the greatest possible information regarding government affairs is accessible to all persons, including those incarcerated (paras 4-13).
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