This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- WildEarth Guardians filed a petition for a writ of mandamus against Tom Blaine, in his capacity as New Mexico State Engineer, concerning the management of water rights and permits. The case involves complex issues related to the authority of multiple federal and state governmental entities over these water rights and permits.
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Petitioner-Appellant (WildEarth Guardians): Argued that the district court’s denial of its petition for writ of mandanus should be reviewed de novo due to questions of statutory interpretation being presented. They contended that a specific statutory provision establishes a clear and indisputable duty on the part of the State Engineer regarding the management of water rights and permits (paras 3, 5).
- Respondent-Appellee (Tom Blaine, New Mexico State Engineer): [Not applicable or not found]
- Real Parties in Interest (Middle Rio Grande Conservancy District, and U.S. Bureau of Reclamation): [Not applicable or not found]
Legal Issues
- Whether the district court’s denial of the petition for writ of mandamus should be reviewed de novo due to questions of statutory interpretation.
- Whether the specific statutory provision invoked by the petitioner establishes a clear and indisputable duty on the part of the State Engineer.
Disposition
- The Court of Appeals affirmed the district court's order denying WildEarth Guardians' petition for writ of mandamus (para 7).
Reasons
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Per VARGAS, J., with MEDINA, J., and IVES, J., concurring:The Court disagreed with the petitioner's assertion that the district court’s denial of the petition for writ of mandamus should be reviewed de novo, maintaining that the standard review is for an abuse of discretion. The Court found no abuse of discretion in the district court's decision, which was based on prudential reasons given the complexity of the situation and the discretion allowed to the State Engineer by statutory and regulatory provisions (paras 3-4).The Court recognized the petitioner's plausible interpretation of the statutory provision but noted that it was not the only possible interpretation. Given the alternative interpretations that permit the State Engineer discretion, the Court concluded that a mandamus action was not appropriate. The Court emphasized that mandamus is only appropriate to compel an official to perform a duty if the duty is clear and indisputable, which was not the case here due to the complexity and lack of clarity regarding the duty to perform as alleged by the petitioner (paras 5-6).
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