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 April 2022, the petitioner's attorney requested from the UNM Hospital Custodian of Records an audit log detailing all persons or entities who had accessed the petitioner's medical records. The request was denied based on IPRA, HIPAA, and other legal grounds. The petitioner then filed a complaint against UNM, alleging a violation of the Inspection of Public Records Act (IPRA) and added a breach of fiduciary duty claim after UNM filed a motion for judgment on the pleadings (paras 2).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Petitioner: Argued that the district court erred by concluding the requested record was not a "public record" under IPRA and that the court abused its discretion by granting UNM's motion for judgment on the pleadings without first ruling on pending discovery motions (para 3).
• Respondent: Contended that the district court's legal conclusion was correct and that the court did not abuse its discretion because the discovery motions would not have aided in deciding the motion for judgment on the pleadings due to its purely legal nature (para 3).

Legal Issues

• Whether the record requested by the petitioner qualifies as a "public record" under the Inspection of Public Records Act (IPRA).
• Whether the district court abused its discretion by granting the respondent's motion for judgment on the pleadings without first ruling on the petitioner's pending discovery motions.

Disposition

• The Court of Appeals affirmed the district court's order dismissing the petitioner's complaint with prejudice (para 1).

Reasons

• The Court of Appeals, with Justice Bosson retired and sitting by designation, along with Judges Wray and Bustamante concurring, found the respondent's arguments persuasive. The court held that the district court correctly granted the motion for judgment on the pleadings under Rule 1-012(B)(6) standards, accepting as true all facts well pleaded and questioning only whether the petitioner might prevail under any state of facts provable under the claim. The court concluded that the audit log requested by the petitioner did not qualify as a "public record" under IPRA because it contained health information that related to and identified specific individuals as patients, which is expressly excluded from public disclosure under IPRA. The court also rejected the petitioner's argument for in camera review and found no error in the district court's dismissal of the complaint based on the arguments presented under IPRA (paras 4-17).