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 the Sandia foothills near Albuquerque, New Mexico, James Boyd was shot and killed by Albuquerque Police Department Detective Keith Sandy on March 16, 2014. Following this incident, the FBI announced an investigation into the shooting to determine if there were any civil rights violations. The Plaintiff, Andrew Jones, requested all records related to the shooting from the New Mexico Department of Public Safety (DPS) under the Inspection of Public Records Act (IPRA). DPS confirmed possession of the records but declined to produce them, citing an ongoing FBI investigation and potential jeopardy to the investigation's integrity (paras 2-3).

Procedural History

• District Court of Bernalillo County, Denise Barela-Shepherd, District Judge: Denied Plaintiff's motion for summary judgment and ruled that the records withheld were excepted from production under IPRA due to an ongoing FBI investigation. It also set conditions for future production and review of the records (para 5).

Parties' Submissions

• Plaintiff: Argued that DPS wrongfully denied his IPRA request for records related to the James Boyd shooting, contending that DPS failed to establish that the records were exempt from disclosure under the law enforcement records exception to IPRA (para 8).
• Defendant (DPS): Responded that the court should not reach the merits of Plaintiff’s appeal on procedural grounds, asserting that Plaintiff had failed to object to the trial court’s order denying his motion for summary judgment, which precluded consideration of his claims on appeal (para 9).

Legal Issues

• Whether DPS failed to satisfy its burden to establish that the records requested by Plaintiff are exempt from disclosure under the law enforcement records exception to IPRA, Section 14-2-1(A)(4) (para 8).

Disposition

• The Court of Appeals affirmed the trial court's order granting DPS's motion for summary judgment, thereby denying Plaintiff's appeal (para 16).

Reasons

• The Court of Appeals, led by Judge Michael E. Vigil with Judges J. Miles Hanisee concurring and Julie J. Vargas dissenting, reasoned that Plaintiff had acquiesced to the trial court's December 9, 2014 order, which effectively amounted to an interlocutory determination that the records withheld were properly excepted from production. The court also noted that the controversy underlying Plaintiff’s IPRA claim became moot when DPS produced the records after the FBI concluded its investigation, as Plaintiff then received the records he sought. Consequently, Plaintiff was not entitled to an award of attorneys’ fees under IPRA (paras 14-15). Judge Vargas, in her dissent, argued that the appeal was not moot upon DPS's production of the documents and that the court should have reached the merits of Plaintiff’s appeal (paras 18-27).