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 undeveloped land in Rio Rancho, New Mexico, filed a land use and takings case against Harold’s Grading & Trucking, Inc. (HGT) and the City of Rio Rancho. HGT's operations allegedly caused a public nuisance by excavating near a public road, creating unsafe conditions, and failing to comply with legal requirements. The City was accused of inverse condemnation by eliminating access to Plaintiffs' properties through road modifications (paras 1, 4-10).

Procedural History

• District Court, Sandoval County: The court found HGT's operations constituted a public nuisance and issued a permanent injunction. A jury found in favor of Plaintiffs on inverse condemnation claims against the City and additional claims against HGT (paras 1, 10).

Parties' Submissions

• Plaintiffs-Appellees: Argued that HGT's operations created a public nuisance and that the City's road modifications amounted to inverse condemnation, warranting attorney fees and costs (paras 1, 10-11).
• Defendants-Appellants (HGT): Sought to reverse the public nuisance determination and modify the injunction, arguing it was too broad and not supported by evidence (paras 1, 12-14).
• Defendants-Appellants (City of Rio Rancho): Contended that attorney fees should not be awarded for inverse condemnation claims, the fee award was unreasonable, and the cost award was unsupported by law (paras 1, 11).

Legal Issues

• Whether HGT's operations constituted a public nuisance.
• Whether the district court's permanent injunction was overly broad.
• Whether attorney fees are available for inverse condemnation claims under New Mexico law.
• Whether the awarded attorney fees and costs were reasonable and lawful (paras 1, 12, 47, 53).

Disposition

• The court affirmed the finding of public nuisance but remanded for modification of the injunction.
• The court upheld the award of attorney fees and costs to Plaintiffs (paras 3, 50, 54, 63).

Reasons

Per Wray J. (Duffy and Yohalem JJ. concurring):

• The court found substantial evidence supporting the district court's determination that HGT's operations unreasonably interfered with public rights and affected community interests. However, the injunction was deemed too broad, as it did not allow HGT to seek authorization to cure the public harm (paras 2, 18-20, 27-30).
• The court held that attorney fees are available for inverse condemnation claims under Section 42A-1-25(A)(3), aligning with precedent that protects landowners from wrongful takings without compensation (paras 3, 48-50).
• The court found the attorney fees and costs awarded were reasonable, as the work against HGT and the City was inextricably intertwined, and the district court did not abuse its discretion in its determinations (paras 54, 60-61).