This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
Blanchard Corona Ranch, LLC (Blanchard) filed a suit against the Commissioner of Public Lands of New Mexico, alleging that the Commissioner violated State Land Office rules by issuing two wind energy leases that overlapped with land previously leased to Blanchard for grazing. Blanchard sought a declaratory judgment that the Commissioner failed to comply with procedural requirements, impacting Blanchard's interests under the existing agricultural lease (paras 1, 3-5).
Procedural History
- District Court: Denied the Commissioner's motion to dismiss for improper venue, concluding that the suit involved Blanchard's interest in land located in Lincoln County (para 6).
- Court of Appeals: Denied the Commissioner's writ of error and application for interlocutory appeal (para 7).
Parties' Submissions
- Petitioner (Commissioner): Argued that venue in Lincoln County was improper because the suit did not have an interest in lands as its object, and that the case should be brought in Bernalillo County or Santa Fe County (paras 6, 9-10).
- Respondent (Blanchard): Contended that venue was proper in Lincoln County as the suit involved an interest in lands, specifically the impact of the wind energy leases on Blanchard's possessory interest under the agricultural lease (paras 10-11).
Legal Issues
- Whether the suit has as its object an interest in lands under Section 38-3-1(D)(1) of New Mexico’s venue statute (para 7).
Disposition
- The Supreme Court of New Mexico reversed the district court's order and remanded to dismiss the case without prejudice for improper venue (para 27).
Reasons
Per Vargas J. (Thomson C.J., Vigil, Bacon, and Zamora JJ. concurring):
The Court concluded that the relief Blanchard sought did not have an interest in lands as its object because it would not affect a current possessory interest or any interest established by the agricultural lease. The Court adopted the holding in Kaywal, Inc. v. Avangrid Renewables, LLC, which stated that a suit has an interest in lands as its object only when the judgment sought could create, transfer, or revoke title or a possessory interest in land. The Court found that the declaratory relief sought by Blanchard would not itself delineate, limit, or alter the parties' property interests and thus did not require the action to be brought in Lincoln County (paras 2, 12-16, 23-26).