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 County of Bernalillo and the City of Albuquerque entered into a Joint Powers Agreement (JPA) in 2002 for the operation of the Metropolitan Detention Center (MDC). The JPA allowed either party to terminate the agreement with at least 12 months' notice before the end of the fiscal year. In April 2005, the Mayor of Albuquerque issued a letter unilaterally terminating the JPA, effective June 30, 2006. The County disputed the Mayor's authority to terminate the JPA without City Council approval (paras 1-3).
Procedural History
- District Court, February 1, 2006: The County filed a complaint for declaratory judgment, arguing that the Mayor lacked unilateral authority to terminate the JPA (para 4).
- District Court, February 22, 2006: The City Council passed Resolution R-06-32, supporting the transfer of MDC operations to the County and the termination of the JPA (paras 6-7).
- District Court, (date unspecified): The court granted summary judgment in favor of the City, holding that the Mayor had the authority to terminate the JPA and that the termination was valid (para 10).
Parties' Submissions
- Appellant (County of Bernalillo): Argued that the Mayor lacked unilateral authority to terminate the JPA without City Council approval. The County also contended that Resolution R-06-32 did not ratify the Mayor’s termination of the JPA (paras 4-5, 9).
- Appellee (City of Albuquerque): Asserted that the Mayor’s termination of the JPA was valid and that the City Council ratified the termination through Resolution R-06-32 (paras 7, 14).
Legal Issues
- Did the Mayor of Albuquerque have the authority to unilaterally terminate the JPA?
- Did the City Council ratify the Mayor’s termination of the JPA through Resolution R-06-32?
Disposition
- The Court of Appeals affirmed the termination of the JPA, holding that the City Council ratified the Mayor’s termination through Resolution R-06-32 (para 22).
Reasons
Per Vigil J. (Sutin C.J. and Castillo J. concurring):
The Court did not address whether the Mayor had unilateral authority to terminate the JPA. Instead, it focused on whether the City Council ratified the termination. The Court found that Resolution R-06-32 explicitly supported the termination of the JPA and the transfer of MDC operations to the County by July 1, 2006. The resolution’s language, combined with the City Council’s failure to repudiate the Mayor’s termination letter, constituted ratification. The Court rejected the County’s argument that the resolution’s conciliatory language negated its ratifying effect. The Court concluded that the City Council’s actions demonstrated approval of the termination, making it valid (paras 14-21).