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 case concerns a dispute over a site development plan submitted by Albuquerque Commons Partnership (ACP) for a property leased in Albuquerque's Uptown area. The property was subject to zoning regulations under the 1981 Uptown Sector Development Plan. In 1995, while ACP's application was under review, the City of Albuquerque enacted a revised Sector Plan, leading to the indefinite deferral of ACP's application. ACP alleged procedural and substantive due process violations, inverse condemnation, and unconstitutional taking after the City denied its application (paras 3-5).

Procedural History

• District Court, July 23, 1999: The court ruled that the City had downzoned ACP's property without providing quasi-judicial review by an impartial decision-maker. It prohibited the application of the 1995 Sector Plan and ordered reconsideration of ACP's application under the 1981 Sector Plan. The court denied summary judgment on ACP's procedural due process claim and dismissed other claims (para 6).
• City Council, March 20, 2000: The City Council denied ACP's site plan application after reconsideration (para 7).
• District Court, June 19, 2001: The court reversed the City Council's decision and directed the City to approve ACP's site plan (para 10).

Parties' Submissions

• Appellant (City of Albuquerque): Argued that the district court's prior orders were interim and not final, and that the district court lacked jurisdiction to issue a final order without resolving all claims, including the pending damages claim (paras 9-10).
• Appellee (ACP): Contended that the City's actions violated its rights under state law, the City Zoning Code, and the U.S. Constitution. ACP sought approval of its site plan and damages for procedural due process violations (paras 5, 8-9).

Legal Issues

• Was the district court's June 19, 2001 order a final, appealable order?
• Did the district court have jurisdiction to issue the order while a damages claim was still pending?

Disposition

• The Court of Appeals vacated the district court's order granting the City's petition for a writ of certiorari and quashed the writ of certiorari (para 13).

Reasons

Per A. Joseph Alarid J. (Bosson C.J. and Bustamante J. concurring):

The Court held that the district court's June 19, 2001 order was not a final, appealable order because ACP's damages claim was still pending before the district court. Under Rule 1-054(B)(1) NMRA, an order that adjudicates fewer than all claims in a case is not final unless certified for immediate appeal, which had not occurred here. The Court emphasized that the district court's prior orders, including the July 23, 1999 order, were interim and subject to revision. The appellate jurisdiction of the Court of Appeals could not be invoked until all claims were resolved or properly certified (paras 11-12).