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 magistrate judge sought retirement benefits under the Public Employees Retirement Act after resigning from one of his two part-time judicial positions. He claimed to have met the requirements for retirement and sought to collect his annuity while continuing to serve in his other judicial role. The Public Employees Retirement Board initially approved his benefits but later rescinded the decision based on advice from the Attorney General (paras 1-2).
Procedural History
- District Court of McKinley County: Issued a permanent writ of mandamus ordering the Public Employees Retirement Board to pay the contested retirement benefits to the magistrate judge (para 1).
Parties' Submissions
- Petitioner-Appellee (Magistrate Judge): Argued that he was entitled to retirement benefits under the Public Employees Retirement Act, having complied with the statutory requirements, including a break in service, and qualified for the elected official exception (paras 1-2, 9-10).
- Respondents-Appellants (Public Employees Retirement Board): Contended that the magistrate judge did not meet the statutory requirements for retirement, including the elected official exception, and that the district court lacked jurisdiction. They also argued that mandamus was not an appropriate remedy (paras 3, 6, 10-12).
Legal Issues
- Did the district court have jurisdiction to hear the case?
- Was the magistrate judge entitled to retirement benefits under the Public Employees Retirement Act?
- Was the issuance of a writ of mandamus appropriate in this case?
- Could the Public Employees Retirement Board be estopped from denying benefits based on prior advice given to the magistrate judge?
Disposition
- The Supreme Court of New Mexico reversed the district court's declaratory judgment and vacated the writ of mandamus (para 24).
Reasons
Per Ransom CJ (Baca and Franchini JJ. concurring):
Jurisdiction: The district court had jurisdiction to hear the case as it involved a declaratory judgment and mandamus, which are within the general jurisdiction of district courts. The Board's actions were not quasi-judicial, and the case did not originate as an appeal (paras 3-5).
Retirement Benefits: The magistrate judge did not qualify for the elected official exception under the Public Employees Retirement Act. The exception applied only to individuals who became elected officials after retiring, not to those continuing in the same elected position. The judge's actions, including a purported break in service, were insufficient to meet the statutory requirements (paras 10-13).
Mandamus: Mandamus was inappropriate because the magistrate judge's entitlement to benefits was not clearly established by law. Mandamus is a coercive remedy for enforcing a clear legal duty, which was not present in this case (paras 6-9).
Estoppel: The Board could not be estopped from denying benefits based on erroneous advice given to the magistrate judge. Estoppel against the state is only applied in exceptional circumstances, and granting benefits contrary to law would undermine public policy. The judge's reliance on the advice was not reasonable, as the Board's initial approval was contingent on legal review (paras 14-22).