This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
R&R, LLC acquired a property known as the "Tularosa Triangle" in 2011, located at the intersection of U.S. Highways 54 and 70 in Tularosa, New Mexico. In 2016, R&R obtained a clear title to the property through a quiet title action. In 2021, R&R entered into a purchase agreement with Maverik, Inc. for $720,000. However, the New Mexico Department of Transportation (NMDOT) claimed ownership of 90% of the property, leading Maverik to terminate the agreement. R&R then filed a complaint against NMDOT for inverse condemnation, slander of title, and intentional interference with contractual relations (paras 2-4).
Procedural History
- District Court, 2016: Granted R&R free and clear title to the property in a quiet title action (para 2).
Parties' Submissions
- Appellant (NMDOT): Argued that it had a prescriptive easement on the property, supported by evidence of public use and maintenance activities. NMDOT also contended that the district court erred in excluding evidence related to the easement, taking judicial notice of the prior quiet title suit, and not precluding the slander of title and interference with contractual relations claims (para 1).
- Appellee (R&R, LLC): Asserted that NMDOT did not have an easement or right-of-way across the property, as evidenced by affidavits and surveys showing no highway use of the property. R&R argued that NMDOT's claims interfered with its property rights and led to the termination of the sale agreement with Maverik (paras 5-7).
Legal Issues
- Whether the district court erred in granting partial summary judgment by finding no prescriptive easement existed on the property.
- Whether the district court erred in excluding evidence related to the prescriptive easement at trial.
- Whether the district court erred in taking judicial notice of the prior quiet title action.
- Whether the district court erred in not precluding the slander of title and intentional interference with contractual relations claims.
Disposition
- The Court of Appeals affirmed the district court's decision on all grounds (para 1).
Reasons
Per Medina J. (Hanisee and Yohalem JJ. concurring):
The court found that NMDOT failed to present sufficient admissible evidence to create a genuine issue of material fact regarding the existence of a prescriptive easement. The evidence provided by NMDOT, including affidavits and maps, did not demonstrate actual use of the disputed area for highway purposes. The court also held that the district court did not err in taking judicial notice of the prior quiet title action, as it did not determine NMDOT's rights based on that suit. Furthermore, the court concluded that R&R effectively proceeded on an inverse condemnation theory, and the district court did not find the State liable for slander of title or intentional interference with contractual relations, thus not violating sovereign immunity or common law principles (paras 13-32).