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 Plaintiff-Appellee filed a petition under the Uniform Owner-Resident Relations Act, seeking restitution of a single-family home in Southwest Albuquerque, alleging the Defendant-Appellant, his tenant, had not paid rent for part of June and all of July 2014. Both parties appeared pro se at trial, and neither requested a recording of the proceedings, resulting in no record of the arguments, testimony, or evidence presented at trial. The metropolitan court ruled in favor of the Plaintiff-Appellee, ordering the Defendant-Appellant to pay past-due rent and costs (paras 3-5).

Procedural History

• The district court dismissed the Defendant-Appellant's appeal due to the absence of a requested recording of the trial, noting the metropolitan court was a court of record for the matter, and without a record, the court could not review the trial for errors (para 6).
• The Defendant-Appellant appealed the dismissal to the Court of Appeals, which was certified to the Supreme Court for review (para 7).

Parties' Submissions

• Defendant-Appellant: Argued that the metropolitan court’s practice of not recording civil proceedings except on a party’s request was inconsistent with statutory requirements and violated his constitutional rights. Sought a new trial and a directive for the metropolitan court to record civil proceedings irrespective of a party’s request (para 1).
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the metropolitan court is required to create a record of all civil proceedings for which it serves as a court of record, irrespective of a party’s request for such a recording (para 1).

Disposition

• The Supreme Court held that the metropolitan court must create a record of its proceedings sufficient to permit appellate review, reversing the district court's dismissal of the appeal and remanding the matter to the metropolitan court for a new trial (paras 2, 40-43).

Reasons

• The Supreme Court, per Chief Justice Bacon, found that the statute imposes a duty on the metropolitan court to create a record of its proceedings to permit appellate review, ruling that Rule 3-708(A) and similar rules conflict with statutory requirements to the extent they condition the creation of this record on a party’s request. The Court directed the committee for the Rules of Civil Procedure for the State Courts to correct the rules in conformance with its opinion. The Court declined to reach constitutional issues raised by the Defendant-Appellant, focusing instead on statutory interpretation. The Court also noted the Legislature's amendment to Section 34-8A-6, which, as of June 14, 2019, specifies that the metropolitan court is a court of record for civil actions other than those under the Uniform Owner-Resident Relations Act, but proceeded to consider the questions as presented based on the statute in effect at the time of the judgment in this matter. The Court issued an administrative order directing the metropolitan court to record all civil proceedings for which the court serves as a court of record, notwithstanding language to the contrary in Rule 3-708 (paras 8-43).