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

The Plaintiff applied for a domestic well permit from the State Engineer in 2003, which was approved. However, the City of Santa Fe had a 1999 ordinance prohibiting wells within 200 feet of a municipal water distribution line. The Plaintiff's property fell within this restriction. The Plaintiff drilled the well without obtaining City authorization, leading to a dispute over the City's authority to regulate domestic wells under its ordinance and state law (paras 2, 5-8).

Procedural History

• District Court, (N/A): Granted summary judgment in favor of the City, holding that the Plaintiff must obtain a City permit before using her domestic well (para 2).
• Stennis v. City of Santa Fe, 2006-NMCA-125: The Court of Appeals affirmed the District Court's decision in a split decision, holding that the City had the authority to enact the 1999 ordinance under its home rule authority (para 2).

Parties' Submissions

• Plaintiff: Argued that the City lacked authority to regulate domestic wells through its 1999 ordinance and that the ordinance was preempted by state law, specifically Section 3-53-1.1, which was enacted in 2001 (paras 2, 11).
• Defendant: Contended that the 1999 ordinance was a valid exercise of the City's home rule authority and that Section 3-53-1.1 did not preempt the ordinance. The City also argued that the Plaintiff failed to exhaust administrative remedies (paras 2, 14, 16).

Legal Issues

• Did the Plaintiff have standing to bring a declaratory judgment action without first applying for City authorization?
• Was the City's 1999 ordinance a valid exercise of its home rule authority?
• Did Section 3-53-1.1 invalidate the City's 1999 ordinance?
• Was the City required to file its 1999 ordinance with the State Engineer to enforce it against the Plaintiff?

Disposition

• The Supreme Court of New Mexico remanded the case to the District Court to determine whether the City filed its 1999 ordinance with the State Engineer before the Plaintiff applied for her domestic well permit (para 4).

Reasons

Per Serna J. (Chávez CJ., Maes J., and Wechsler J. concurring):

• Standing: The Court held that the Plaintiff had standing to bring a declaratory judgment action because she was challenging the validity of the City's ordinance, not circumventing administrative procedures (paras 14-15).
• Home Rule Authority: The Court reaffirmed its prior decision in Smith v. City of Santa Fe, holding that the City had the authority to enact the 1999 ordinance under its home rule powers (para 15).
• Section 3-53-1.1: The Court concluded that Section 3-53-1.1 did not invalidate the 1999 ordinance, as the statute did not require municipal ordinances to track its language. However, the City was required to file the ordinance with the State Engineer under Section 3-53-1.1(D) (paras 16-24).
• Remand: The Court remanded the case to determine whether the City had filed the 1999 ordinance with the State Engineer before the Plaintiff applied for her well permit. If the ordinance was filed, the Plaintiff must seek City authorization. If not, the City lacked authority to regulate the Plaintiff's well (para 24).