This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
Two members of the New Mexico Legislature petitioned the court to challenge the wording of a ballot question under the 1992 Capital Projects General Obligation Bond Act. The Act authorized state debt for various projects, including senior citizen facilities, educational improvements, and water rights acquisitions. The petitioners argued that the projects lacked a common purpose and should be presented as separate questions to voters, as required by the New Mexico Constitution to prevent "logrolling" (paras 1-2).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Petitioners (Representatives Ryan and Lujan): Argued that the 1992 Bond Act violated Article IX, Section 8 of the New Mexico Constitution by combining unrelated projects into a single ballot question, thereby engaging in impermissible "logrolling." They contended that each project should be presented as a separate question to voters (paras 1, 6).
- Respondent (Secretary of State): Asserted that the projects were interrelated and served the overarching purpose of improving public welfare. The legislature had determined that the projects were necessarily related and should be presented as a unified ballot question (paras 6-8).
Legal Issues
- Whether the 1992 Capital Projects General Obligation Bond Act violated Article IX, Section 8 of the New Mexico Constitution by combining multiple unrelated projects into a single ballot question.
- Whether the legislature's determination of the relatedness of the projects should be given deference.
Disposition
- The court issued a writ of mandamus requiring the Secretary of State to present the projects as nine separate questions on the ballot (para 1).
Reasons
Per Ransom CJ (Baca, Montgomery, and Franchini JJ. concurring):
The court held that Article IX, Section 8 of the New Mexico Constitution requires that state debt be authorized for "some specified work or object" and prohibits "logrolling," which forces voters to approve or reject unrelated projects as a single proposition. The court found that the projects in the 1992 Bond Act lacked a logical or necessary interrelationship and did not form a single, unified purpose. The legislature's findings of relatedness were insufficient to meet the constitutional standard, as the projects were only connected by the broad goal of public welfare, which is too general to satisfy the "specified work or object" requirement. The court concluded that presenting the projects as separate questions would better align with the constitutional intent to allow voters to approve or reject each project independently (paras 5-10).
Dissenting: Frost J.
Justice Frost dissented, arguing that the majority's interpretation of Article IX, Section 8 was overly narrow and failed to respect the legislature's determination of relatedness. Frost emphasized the importance of deferring to legislative findings and warned that requiring separate ballot questions for each project would lead to excessively lengthy ballots and undermine equitable state-wide funding. Frost also noted that other jurisdictions have upheld similar bond acts under comparable constitutional provisions and that the legislature's determination of interrelatedness should have been upheld (paras 11-19).