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 Plaintiffs were each convicted of driving while intoxicated (DWI) on three separate occasions. Their most recent convictions were entered in the Silver City Municipal Court. Following these convictions, the Motor Vehicle Division of the New Mexico Taxation and Revenue Department revoked their driver's licenses pursuant to statutory provisions. The Plaintiffs argued that they were sentenced as "first offenders" for their most recent convictions and that the Department was bound by this determination, precluding longer license revocation periods (paras 2-3).
Procedural History
- District Court of Santa Fe County, March 18, 1997: The court granted summary judgment in favor of the Department, holding that the Plaintiffs were ineligible for driver's licenses due to their three DWI convictions within a ten-year period (para 4).
Parties' Submissions
- Plaintiffs-Appellants: Argued that the Department was bound by the Silver City Municipal Court's determination that they were "first offenders" for their most recent DWI convictions. They contended that the Department could not deny their license applications for more than one year and sought a declaratory judgment restoring their driving privileges (paras 3, 10).
- Defendants-Appellees: Asserted that the Plaintiffs were ineligible for driver's licenses under NMSA 1978, Section 66-5-5(D), which prohibits licensure for individuals with three DWI convictions within a ten-year period. They argued that the Plaintiffs had not followed the administrative procedures required to challenge the denial of their licenses (paras 4, 9).
Legal Issues
- Did the district court have subject-matter jurisdiction to hear the Plaintiffs' declaratory judgment action?
- Were the Plaintiffs entitled to have their driving privileges restored despite their three DWI convictions within a ten-year period?
Disposition
- The district court's order was set aside for lack of subject-matter jurisdiction (para 11).
Reasons
Per Armijo J. (Hartz CJ. and Bosson J. concurring):
The Court held that the district court lacked subject-matter jurisdiction because the Plaintiffs failed to exhaust the administrative remedies required under the Motor Vehicle Code. Specifically, the Plaintiffs did not apply for a driver's license after the expiration of the one-year revocation period or pursue the administrative appeal process outlined in Section 66-2-17 of the Code. The Court emphasized that jurisdictional defects cannot be waived and must be addressed even if raised sua sponte (paras 5-6, 9-10).
The Court clarified that the Plaintiffs' procedural failure precluded judicial review of their claims. However, it noted that the Plaintiffs could still apply for a license and challenge any denial through the proper administrative channels. The Court also stated that its decision did not preclude the Department from raising the issue of the Plaintiffs' ineligibility for licensure in future proceedings (paras 10-11).