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 San Juan Water Commission, composed of San Juan County, three municipalities, and a rural water users association, sought judicial confirmation of two contracts with the United States Bureau of Reclamation (BOR) for the construction of the Animas-La Plata Water Project. The contracts were challenged by the Animas River Agricultural Water Users Association and others, who argued issues such as lack of consideration, lack of capacity to contract, and jurisdictional deficiencies (paras 2-3).
Procedural History
- District Court of San Juan County: Granted summary judgment in favor of the San Juan Water Commission, confirming the contracts and denying the motion to join additional parties (paras 1, 3).
Parties' Submissions
- Respondents-Appellants (Animas River Agricultural Water Users Association and others): Argued that the trial court lacked subject matter jurisdiction, failed to join necessary parties, and that the Commission lacked authority to contract with the BOR. They also contended that the funding mechanism violated statutory and constitutional provisions and that material facts regarding water availability were in dispute (paras 4-6, 21).
- Petitioner-Appellee (San Juan Water Commission): Asserted that the trial court had jurisdiction under the Declaratory Judgment Act, that joinder of additional parties was unnecessary, and that the Commission had authority to contract under the Joint Powers Agreements Act. They also argued that the funding mechanism was lawful and that disputes over water availability were immaterial to the validity of the contracts (paras 7-22).
Legal Issues
- Did the trial court have subject matter jurisdiction under the Declaratory Judgment Act?
- Was the failure to join additional parties a jurisdictional defect?
- Did the San Juan Water Commission have the authority to contract with the BOR?
- Was the funding mechanism for the contracts lawful?
- Were there material facts in dispute that precluded summary judgment?
Disposition
- The Supreme Court of New Mexico affirmed the district court's decision, upholding the validity of the contracts and the grant of summary judgment in favor of the San Juan Water Commission (para 1).
Reasons
Per Frost J. (Ransom C.J. and Baca J. concurring):
Subject Matter Jurisdiction: The trial court properly exercised jurisdiction under the Declaratory Judgment Act. Although the Commission did not explicitly plead jurisdiction under the Act, its request for declaratory relief and the Association's own motion for a declaration of invalidity demonstrated that the issue was litigated with implied consent. The Association was not prejudiced by the amendment of pleadings to conform to the evidence (paras 7-11).
Joinder of Parties: The court held that joinder of all taxpayers and water users was unnecessary under Rule 19. The Declaratory Judgment Act does not require the inclusion of every potentially interested party, and complete relief could be granted to the existing parties without creating a risk of multiple lawsuits (paras 12-13).
Authority to Contract: The Commission had authority under the Joint Powers Agreements Act, which allows public agencies to jointly exercise powers, including contracting with the federal government for water rights. The individual members of the Commission passed resolutions authorizing the contracts, satisfying statutory requirements (paras 14-15).
Funding Mechanism: The use of ad valorem taxes to fund the contracts was lawful. The court distinguished between funding for water rights and water systems, holding that Section 72-4-8, which restricts funding for water systems, did not apply to the acquisition of water rights. The Bateman Act was also inapplicable because the funds were derived from a special mill levy, not general funds (paras 16-20).
Material Facts in Dispute: The court found that disputes over the availability of unappropriated water were immaterial to the validity of the contracts. Such issues pertain to potential future breaches, not the formation of the contracts, and thus did not preclude summary judgment (paras 21-22).