AI Generated Opinion Summaries

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 sought to compel the Appellees to produce records, including a personnel file and an internal affairs file, under the New Mexico Inspection of Public Records Act (IPRA). The district court determined these documents were exempt from IPRA disclosure requirements.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellant: Argued that the documents related to an internal affairs investigation should not be exempt from disclosure under IPRA, asserting there is no privacy interest in the withheld documents and that the public interest in open government outweighs non-disclosure.
• Respondents-Appellees: [Not applicable or not found]

Legal Issues

• Whether the documents requested by the Plaintiff, related to a personnel file and an internal affairs file, are exempt from disclosure under the New Mexico Inspection of Public Records Act (IPRA).

Disposition

• The Court of Appeals affirmed the district court's decision to deny the Plaintiff's petition for writ of mandamus.

Reasons

• Per Jonathan B. Sutin, with Michael E. Vigil, Chief Judge, and Michael D. Bustamante, Judge concurring:
  The Court found that the documents in question were properly withheld under Section 14-2-1(A)(3) of IPRA, which exempts documents concerning disciplinary action and other matters of opinion from disclosure. The Court noted that the documents were created for internal disciplinary proceedings, fitting the exemption criteria (paras 2-4). The Plaintiff's argument that the documents should not be considered exempt because they were not specifically listed in a previous case was rejected, with the Court explaining that the list in the cited case was illustrative, not exhaustive (para 5). The Court also dismissed the Plaintiff's arguments against the privacy interest recognized by the legislature and the applicability of the "rule of reason," citing legislative specificity in exemptions to disclosure and the inapplicability of the rule of reason due to these specific exemptions (paras 6-7). Lastly, the Court addressed the Plaintiff's argument regarding the breadth of his request for "any and all records" related to a specific police officer, finding that the request lacked the "reasonable particularity" required by IPRA and that some requested documents had been produced or could be produced upon a more specific request (para 8).