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

• In January 2017, the Plaintiff requested the New Mexico Department of Game and Fish (NMDGF) to provide the names and email addresses of individuals who applied for hunting licenses in 2015 and 2016. NMDGF agreed to release only the names, arguing that the email addresses did not constitute a public record subject to disclosure under the Inspection of Public Records Act (IPRA). The Plaintiff then filed a lawsuit seeking an order to compel NMDGF to release the email addresses (paras 1-2).

Procedural History

• District Court of Torrance County: The court granted the Plaintiff's motion for summary judgment, compelling NMDGF to produce the email addresses, ruling that they were public records under IPRA (para 1).

Parties' Submissions

• Plaintiff: Argued that the email addresses collected by NMDGF for hunting license applications are public records under IPRA, as they are used by NMDGF to carry out its official licensing acts and relate to the public business of managing public resources (para 6).
• Defendant (NMDGF): Contended that the email addresses are not "public records" because they do not relate to public business as defined in IPRA, asserting that they are personal contact information taken for administrative convenience and their disclosure would infringe on the privacy of New Mexico citizens (para 5-6).

Legal Issues

• Whether the email addresses of individuals who applied for hunting licenses are "public records" subject to disclosure under the Inspection of Public Records Act (IPRA) (paras 3, 5).

Disposition

• The Court of Appeals affirmed the district court’s order granting summary judgment in favor of the Plaintiff, compelling NMDGF to produce the email addresses (para 15).

Reasons

• Per VANZI, J., with VARGAS, J., and MEDINA, J., concurring:
  The court held that the purpose of IPRA is to ensure the public has the greatest possible information regarding government affairs and the official acts of public officers and employees. Under IPRA, public records are broadly defined to include all materials related to public business, without an express exemption from disclosure (paras 4-5, 7-9).
  The court rejected NMDGF's argument that the email addresses do not relate to public business, emphasizing that IPRA's definition of "public records" is broad and includes information collected from the public by a governmental agency in connection with the administration of its public duties. The court found that the email addresses collected by NMDGF in connection with its licensing system constitute "public records" subject to disclosure under IPRA in the absence of an applicable exception (paras 8-11).
  The court also noted that NMDGF did not contend that there is an applicable exception to disclosure under IPRA, and the court could not identify one. The court concluded that accepting NMDGF's position would be tantamount to creating an additional policy-based exception not identified in IPRA or other statutes, which is not permitted (paras 12-14).