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

• Plaintiffs, owners of real property, filed a case against Defendants, tenants of Ascension Financial Group, LLC, and the owner of the burdened estate, to prevent them from blocking access to Plaintiffs’ property with a gate and construction materials. The dispute extended to Plaintiffs' claim of entitlement to use a particular area for parking at a nearby local cemetery based on express or implied public dedication. The parties resolved the access easement dispute by agreeing to a permanent injunction and easement appurtenant, leaving unresolved the parking entitlement and attorney fees claims (para 1).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiffs: Argued for an injunction to remove obstructions blocking their easement, recognition of their right to park at the cemetery based on public dedication, and sought attorney fees for frivolous litigation and bad faith by Defendants (paras 2, 4).
• Defendants: Erected a gate blocking Plaintiffs' easement and opposed the claims regarding parking entitlement at the cemetery. They also contested the motion for attorney fees, arguing the litigation was not frivolous or in bad faith (paras 2, 4, 20).

Legal Issues

• Whether the district court erred by appointing a special master under Rule 1-053 NMRA.
• Whether the district court was required to hold an in-person hearing before adopting the special master’s recommendations.
• Whether Plaintiffs’ public dedication claims were properly dismissed for lack of necessary parties.
• Whether the district court abused its discretion in denying Plaintiffs’ request for attorney fees (para 8).

Disposition

• The district court's appointment of a special master and its decision not to hold an in-person hearing on Plaintiffs' objections were upheld.
• The denial of attorney fees to Plaintiffs was affirmed.
• The dismissal of Plaintiffs’ public dedication claim was reversed, and the case was remanded to determine if necessary parties must be joined (paras 27-28).

Reasons

• Special Master Appointment: The court found no error in appointing a special master, noting Plaintiffs waived any objection by participating without protest and accepting favorable rulings (paras 9-11).
  In-Person Hearing Requirement: The court held that written objections, responses, and a full record submission sufficed for review without an in-person hearing, aligning with Supreme Court precedent (paras 12-15).
  Denial of Attorney Fees: The court agreed with the special master that Defendants’ defense was not frivolous, as they argued the gate did not block access since Plaintiffs were given a key. Pre-litigation conduct was deemed irrelevant to the fees determination, and the voluntary withdrawal of counterclaims by Defendants negated the need for sanctions (paras 16-22).
  Public Dedication Claims: The court found the dismissal premature, suggesting Plaintiffs should have the opportunity to present evidence of implied public dedication or to join necessary parties if the claim involved a dedication to the county. The case was remanded for further proceedings to address these issues (paras 24-26).