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

• Western Agriculture, Resource and Business Advocates, LLP (Plaintiff) appealed an adverse summary judgment related to a dispute involving the New Mexico Attorney General Hector Balderas and Custodian of Records Brittney Martinez (Defendants). The core of the dispute revolved around the application of the Inspection of Public Records Act (IPRA) and the common interest doctrine in the context of communications that the Plaintiff sought to inspect.

Procedural History

• Appeal from the District Court of Bernalillo County, Valerie A. Huling, District Judge, September 10, 2018: The district court issued a summary judgment in favor of Defendants.

Parties' Submissions

• Plaintiff: Argued generally about the importance of the Inspection of Public Records Act (IPRA) but did not specifically address the legal and factual bases of the proposed summary disposition related to the common interest doctrine and its application to the communications in question (para 4).
• Defendants: Filed a memorandum in support of the proposed summary disposition, presumably defending the district court's application of the common interest doctrine and its decision that there was no basis to distinguish between the various communications for purposes of IPRA (para 1).

Legal Issues

• Whether the common interest doctrine requires any particular agreement or contract and if its application is limited to parties in ongoing litigation.
• Whether there is a temporal limitation on the application of the common interest doctrine.
• Whether, under the undisputed facts, there was a basis upon which the Defendants’ custodian or the district court could have distinguished between the various communications at issue for purposes of the Inspection of Public Records Act (IPRA).

Disposition

• The Court of Appeals affirmed the summary judgment entered by the District Court of Bernalillo County in favor of Defendants (para 5).

Reasons

• J. MILES HANISEE, Judge, with concurrence from MICHAEL E. VIGIL, Judge, and STEPHEN G. FRENCH, Judge, reasoned that the Plaintiff failed to establish any dispute as to material facts in response to the motion for summary judgment in the district court. The appellate analysis was limited to whether Defendants were entitled to judgment as a matter of law based on the undisputed facts. The Court proposed to conclude that the common interest doctrine does not require any particular agreement or contract, its application is not limited to parties in ongoing litigation, and there is no temporal limitation on the doctrine. The Court also found that under the undisputed facts, there was no basis to distinguish between the various communications for purposes of IPRA. Plaintiff's failure to address these issues in their memorandum in opposition to the proposed summary disposition led to the issues being deemed abandoned, and the Plaintiff did not meet its burden on appeal (paras 2-4).