This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A former state prisoner at a New Mexico Corrections Department (NMCD) facility filed a claim under the New Mexico Inspection of Public Records Act (IPRA) against Centurion Correctional Healthcare of New Mexico, LLC, a private company contracted to provide healthcare services to inmates. The plaintiff requested records related to settlements, judgments, and litigation costs involving the defendant, but the defendant did not respond, claiming it was not subject to IPRA (paras 2-5).
Procedural History
- District Court, May 11, 2020: The district court granted the defendant's motion to dismiss the plaintiff's complaint in its entirety.
- New Mexico Court of Appeals, (N/A): The Court of Appeals remanded the case to the district court for findings related to the IPRA request issues.
- District Court, (N/A): The district court denied the defendant's motion to dismiss the plaintiff's IPRA claim.
Parties' Submissions
- Plaintiff-Appellant: Argued that the district court improperly granted summary judgment in favor of the defendant, asserting that the defendant failed to raise any genuine issue of material fact regarding its responsibility under IPRA (paras 1, 9).
- Defendant-Appellee: Contended that the district court's order was not a final order and that it was not a proper target for an IPRA request, as it was not a records custodian for NMCD or any other New Mexico public body (paras 6, 10).
Legal Issues
- Whether the district court's order granting summary judgment was a final order.
- Whether the defendant was subject to IPRA and had a duty to provide the requested records.
Disposition
- The New Mexico Court of Appeals affirmed the district court's order granting summary judgment in favor of the defendant (para 15).
Reasons
Per Bogardus J. (Medina J. concurring): The court found that the order was a final order because the only remaining issue was related to the plaintiff's IPRA claim. The court concluded that the plaintiff admitted the defendant was not a records custodian, which was necessary for IPRA compliance. Therefore, the district court's grant of summary judgment was appropriate as the plaintiff failed to name a proper records custodian (paras 6-14).
Henderson J., dissenting: Argued that the district court's order was not final as it did not dispose of all issues of law and fact. The dissent emphasized that the order allowed the plaintiff to amend the complaint to name a proper records custodian, indicating non-finality. Additionally, the dissent disagreed with the majority's interpretation of the plaintiff's admission, arguing that the core issue was whether the defendant was a public body required to designate a records custodian (paras 17-28).