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

• Petitioners opposed the development of the proposed Santolina planned community on Albuquerque’s west side mesa in Bernalillo County, leading to consolidated appeals. The development involved a master plan and a zone map amendment for approximately 13,800 acres of land, aiming to establish a vision and framework for the community. The Board of County Commissioners approved the master plan, zone map amendment, and a development agreement with the landowners, sparking legal challenges from the petitioners based on procedural and due process concerns.

Procedural History

• District Court of Bernalillo County: Affirmed the Board's approval of the master plan as legislative action, reversed and remanded the approval of the zone map amendment due to due process concerns regarding a commissioner's potential bias, and dismissed the appeal of the development agreement for lack of ripeness (paras 11, 14).
• Certiorari Denied, April 16, 2021, No. S-1-SC-38653; Conditional Cross-Petition Denied, April 16, 2021, No. S-1-SC-38653. Released for Publication August 31, 2021.

Parties' Submissions

• Petitioners: Argued that the Board's proceedings to approve the master plan were quasi-judicial, not legislative, and that the district court erred in not reviewing the Board’s approval of the development agreement due to the absence of a final written decision from the Board.
• Respondents: Contended that the Board’s approval of the zone map amendment was legislative in nature, requiring fewer procedural protections, and that even if the proceedings were quasi-judicial, the op-ed by Commissioner De La Cruz did not demonstrate impermissible bias.

Legal Issues

• Whether the Board's proceedings regarding the master plan were legislative or quasi-judicial.
• Whether the Board's approval of the zone map amendment was quasi-judicial and if due process was violated due to a commissioner's potential bias.
• Whether the development agreement constitutes zoning and if its approval was a zoning decision.
• Whether the district court had jurisdiction to review the Board's approval of the development agreement in the absence of a final, written order.

Disposition

• The district court's rulings were affirmed, and the zone map amendment was remanded to the Board for further proceedings consistent with the opinion.

Reasons

• The Court found that the Board's proceedings regarding the master plan were legislative, given the broad, area-wide policy regarding future development (paras 17-24).
  The Court held that the Board's proceedings regarding the zone map amendment were quasi-judicial, affecting a specific area of identifiable property, and remanded due to concerns of partiality and prejudgment by Commissioner De La Cruz (paras 25-41).
  The development agreement was determined not to constitute zoning, and its approval was not a zoning decision. The Court also found no violation of the Open Meetings Act in the negotiation and approval of the development agreement (paras 42-53).
  The Court concluded that the lack of a final, written order precluded the district court's review of the Board's approval of the development agreement and that the enactment of the zone map amendment did not require the development agreement to be simultaneously approved (paras 54-55).