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

• Plaintiffs, WildEarth Guardians and the parents of Akilah Sanders-Reed, filed a civil complaint against the State of New Mexico and Governor Susana Martinez, seeking a declaration that the state has a duty under the public trust doctrine to regulate greenhouse gas emissions to protect the atmosphere. The complaint was filed in response to the State's repeal of greenhouse gas regulations, which plaintiffs argued was insufficient to meet the State's public trust duty to protect the atmosphere (paras 2-8).

Procedural History

• District Court of Santa Fe County, Sarah M. Singleton, District Judge: Granted summary judgment in favor of the State, concluding that the public trust doctrine did not apply because the Legislature had established a statutory and administrative scheme for protecting the atmosphere (para 8).

Parties' Submissions

• Plaintiffs-Appellants: Argued that the common law public trust doctrine imposes a duty on the State to regulate greenhouse gas emissions to protect the atmosphere. They contended that the State's failure to regulate these emissions and to devise a plan to mitigate the effects of climate change constituted a breach of its public trust duty (paras 2-3, 7-8).
• Defendants-Appellees: Asserted that the public trust doctrine did not apply as the Legislature and its statutory delegate, the Environmental Improvement Board (EIB), had established appropriate regulatory procedures to protect the atmosphere. They argued that the EIB's decision-making process, including the repeal of greenhouse gas regulations, was a political decision not subject to court intervention (paras 8-9, 17-18).

Legal Issues

• Whether the common law public trust doctrine imposes a duty on the State to regulate greenhouse gas emissions to protect the atmosphere.
• Whether the State's repeal of greenhouse gas regulations and failure to devise a plan to mitigate the effects of climate change constituted a breach of its public trust duty.

Disposition

• The Court of Appeals of New Mexico affirmed the district court's order granting summary judgment in favor of the State (para 19).

Reasons

• The Court, per Judge Timothy L. Garcia, with Chief Judge Michael E. Vigil and Judge J. Miles Hanisee concurring, held that the courts cannot independently impose a common law public trust duty upon the State to regulate greenhouse gases in the atmosphere. The decision was based on several reasons:
  The Air Quality Control Act provides adequate procedures for addressing and implementing any regulation of greenhouse gases, thus precluding a separate common law cause of action under the public trust doctrine (paras 12-18).
  The Legislature's statutory framework supersedes the common law to the extent that it covers the duty or right asserted, including the protection of the atmosphere (paras 16-17).
  Adhering to the plaintiffs' request for a judicial decision that independently regulates greenhouse gas emissions would violate established separation-of-powers principles, as it would supplant the procedures established under the Air Quality Control Act (para 18).
  The Court concluded that while the State has a duty to protect the atmosphere under Article XX, Section 21 of the New Mexico Constitution, this duty must be pursued within the existing constitutional and statutory framework, not through a separate common law cause of action based on the public trust doctrine (para 19).