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 Village of Angel Fire and the Board of County Commissioners of Colfax County entered into a Joint Powers Agreement (JPA) in 2001, under which the Village agreed to provide trash collection services to certain county residents in exchange for $50,000 annually, paid in two installments. The County ceased payments in July 2004 but allegedly promised to resume payments while restructuring its finances. The Village continued providing services until 2007, when it filed a lawsuit for breach of contract, equitable estoppel, and quantum meruit (paras 1, 6-7).

Procedural History

• District Court of Colfax County, October 30, 2007: The court granted the County’s motion for judgment on the pleadings, holding that the Village’s claims were barred by the two-year statute of limitations under NMSA 1978, Section 37-1-23(B) (paras 2, 11).

Parties' Submissions

• Appellant (Village of Angel Fire): Argued that the JPA was an installment contract, with the statute of limitations accruing separately for each missed payment. It also claimed equitable estoppel should prevent the County from asserting the statute of limitations and sought recovery under quantum meruit for services rendered (paras 3, 12).
• Appellee (Board of County Commissioners of Colfax County): Asserted that the Village’s claims were barred by the statute of limitations, the JPA was invalid due to lack of required state approval, and sovereign immunity barred recovery under quantum meruit (paras 2, 10).

Legal Issues

• Was the Village’s claim barred by the two-year statute of limitations under NMSA 1978, Section 37-1-23(B)?
• Should equitable estoppel prevent the County from asserting the statute of limitations?
• Can the Village recover under the doctrine of quantum meruit despite sovereign immunity?

Disposition

• The Court of Appeals affirmed the district court’s judgment on the pleadings in favor of the County (para 28).

Reasons

Per Kennedy J. (Fry CJ and Vanzi J. concurring):

• Statute of Limitations: The Village failed to preserve its argument that the JPA was an installment contract. The court held that the statute of limitations began to run when the County first failed to pay in July 2004. The Village’s claims, filed in 2007, were therefore time-barred (paras 14-18).

• Equitable Estoppel: The Village did not sufficiently plead the elements of equitable estoppel. The County’s alleged promises to pay and secure state approval did not toll the statute of limitations, as the Village was aware of the breach and the lack of approval. The court found no “shocking degree of aggravated and overreaching conduct” to justify estoppel against a government entity (paras 19-25).

• Quantum Meruit: Sovereign immunity under Section 37-1-23(A) barred the Village’s claim for quantum meruit. The court rejected the argument that sovereign immunity does not apply between two governmental entities, as no supporting authority was cited (paras 26-27).