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

• The case involves challenges to the State of New Mexico's public health orders (PHOs) issued in response to the COVID-19 pandemic. These orders imposed restrictions on mass gatherings and the operations of certain businesses, including occupancy limits and closures, to mitigate the spread of the virus. A group of small businesses and business owners, referred to as Real Parties, brought lawsuits against the State, claiming entitlement to just compensation for the alleged takings and damages caused to their private property by the PHOs (paras 8-9).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Petitioners: Argued that the PHOs are a proper exercise of the State’s police power to protect public health and, as such, cannot constitute a taking requiring compensation under the New Mexico Constitution or the Public Health Emergency Response Act (PHERA). They also contended that claimants must exhaust administrative remedies before seeking judicial relief (paras 18, 61-62).
• Real Parties: Contended that the deprivations of private property under the PHOs cannot be justified merely as a regulatory police exercise ineligible for compensation. They argued for a broad interpretation of the compensation provision under PHERA and claimed that the administrative process for compensation is futile (paras 19, 62-63).

Legal Issues

• Whether the State’s public health orders can support a claim for just compensation under either the New Mexico Constitution or the Public Health Emergency Response Act (PHERA) (para 1).
• Whether claimants for just compensation under PHERA must exhaust administrative remedies before seeking judicial relief (para 1).

Disposition

• The Supreme Court of New Mexico held that the PHOs cannot support a claim for a regulatory taking requiring compensation under the New Mexico Constitution or PHERA. It further held that claimants must exhaust administrative remedies set forth in PHERA before seeking judicial relief (para 80).

Reasons

• The Court reasoned that the PHOs are a reasonable exercise of the State’s police power aimed at protecting public health during the COVID-19 pandemic. It determined that the restrictions on business operations, such as occupancy limits and closures, are directly tied to the purpose of limiting public exposure to the disease and are therefore not compensable takings under the New Mexico Constitution or PHERA. The Court also found that the legislative intent of PHERA's compensation provision does not extend to the broad interpretation proposed by the Real Parties, limiting "any other property" to property directly taken or appropriated by the State for use in a public health emergency. Additionally, the Court emphasized the necessity for claimants to exhaust administrative remedies as a prerequisite for judicial review, aligning with the statutory requirements of PHERA (paras 34-79).