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 case involves an appeal by Defendants-Appellants (Appellants) against the district court's dismissal of their claims to water rights in the Lower Rio Grande stream system. The claims are based on rights derivative of the Rio Grande Dam and Irrigation Company (the Company), which was involved in a historical legal battle over the completion of an irrigation project initiated in the 1890s. The United States had previously sued the Company, leading to a forfeiture judgment against the Company for not completing the project within the stipulated time. The Appellants, claiming to be successors in interest to pre-1893 farmers who had agreements with the Company, sought to assert water rights based on these historical claims (paras 2-6).

Procedural History

• United States v. Rio Grande Dam & Irrigation Co. (Rio Grande Dam II), 1906-NMSC-013: Affirmed a default judgment against the Company for forfeiture of rights to complete the irrigation project.
• Boyd v. United States (Boyd I), No. 96-476L, slip op. (Fed. Cl. Apr. 21, 1997): Rejected the Boyd Estate’s taking claim regarding the irrigation rights.
• Boyd Estate ex rel. Boyd v. United States (Boyd Estate), 2015-NMCA-018: Dismissed the Boyd Estate’s claim to the Company’s original water rights.
• State ex rel. Off. of State Eng’r v. Boyd (Boyd II), A-1-CA-36291, mem. op. (N.M. Ct. App. June 24, 2021): Affirmed the district court’s order striking the Boyd Estate’s notice of intent to participate in a stream system issue.

Parties' Submissions

• Appellants: Argued that the district court erred in dismissing their claims under res judicata principles, contended the forfeiture judgment was void due to lack of jurisdiction by the 1903 district court, and claimed they were improperly denied the opportunity to collaterally attack the forfeiture judgment by reasserting allegations of fraud.
• Appellee (State of New Mexico, the United States of America, and EBID): Filed a joint motion to dismiss Appellants’ claims on the basis that they failed to state a basis for a water right under New Mexico law and argued that Appellants’ claims were precluded by res judicata.

Legal Issues

• Whether the district court erred in dismissing Appellants’ claims under res judicata principles.
• Whether the forfeiture judgment is void due to the alleged lack of jurisdiction by the 1903 district court.
• Whether Appellants were improperly denied the opportunity to collaterally attack the forfeiture judgment by reasserting allegations of fraud.

Disposition

• The Court of Appeals affirmed the district court’s order dismissing Appellants’ claims to water rights in the Lower Rio Grande stream system (para 1).

Reasons

• Per J. Miles Hanisee, with concurrence from Jane B. Yohalem and Katherine A. Wray, the court held that the Appellants’ claims were barred by res judicata, noting that the issues raised had been previously litigated and decided against similar parties in related cases. The court found no error in the district court's application of res judicata, stating that the Appellants, claiming to be successors in interest to the pre-1893 farmers and thereby in privity with the Company, were bound by the forfeiture judgment and subsequent rulings. The court also rejected Appellants' arguments regarding the alleged fraud and lack of jurisdiction in the forfeiture judgment, citing previous decisions that addressed and dismissed these claims. The court concluded that the district court correctly dismissed the Appellants’ claims for failing to state a basis for a water right under New Mexico law and for being precluded by res judicata (paras 8-17).