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 the approval of a commercial development project, Entrada Contenta, in Santa Fe, which included a Wal-Mart Superstore and 16 other businesses. Petitioners, comprising small business owners and others, opposed the development, citing concerns about its economic impact on existing businesses and the community. They alleged that the Santa Fe City Council improperly limited its review to compliance with the land development code, excluding broader considerations such as economic effects and public interest (paras 1, 3, 5).
Procedural History
- District Court, Santa Fe County: The district court upheld the Santa Fe City Council’s approval of the Entrada Contenta development, rejecting Petitioners’ claims that the Council’s decision was arbitrary, capricious, or violated due process (headnotes, para 1).
Parties' Submissions
- Petitioners-Appellants: Argued that the City Council improperly limited its review to land development code compliance, influenced by incorrect advice from the City attorney. They contended that this limitation rendered the Council’s decision arbitrary and capricious. They also claimed that the public was not adequately informed about the scope of the Council’s review, violating due process rights (paras 3, 6, 8, 10).
- Respondents-Appellees: Asserted that the Council’s decision was lawful and supported by substantial evidence. They argued that the affidavits of three councilors, submitted by Petitioners to supplement the record, were inadmissible as they were not part of the original administrative proceedings (paras 7, 9, 11).
Legal Issues
- Was the Santa Fe City Council’s decision to approve the Entrada Contenta development arbitrary and capricious?
- Did the district court err in striking the affidavits of three City councilors from the record?
- Did the alleged lack of public notice regarding the scope of the Council’s review violate Petitioners’ due process rights?
Disposition
- The Court of Appeals affirmed the district court’s decision, upholding the Santa Fe City Council’s approval of the Entrada Contenta development (para 44).
Reasons
Per Robles J. (Fry CJ and Sutin J. concurring):
Affidavits: The court held that the district court correctly struck the affidavits of three councilors because Rule 1-074 does not permit supplementation of the administrative record with new evidence created for appeal. The affidavits were not part of the original proceedings and were unnecessary, as the record already contained sufficient evidence to address Petitioners’ claims (paras 11-14, 18-20).
Arbitrary and Capricious Decision: The court found no evidence that the Council limited its review solely to land development code compliance. The record demonstrated that councilors considered broader issues, including economic impacts and public interest. Statements made by councilors during the hearing reflected a range of considerations beyond land use regulations. The court concluded that the Council’s decision was reasonable and supported by substantial evidence (paras 21-30, 33-36).
Due Process: The court rejected Petitioners’ due process claim, noting that the public hearing allowed extensive discussion of issues beyond land development code compliance. Members of the public and councilors addressed various concerns, and there was no indication that public participation was restricted or that the Council failed to consider relevant issues (paras 37-42).
The court emphasized that Petitioners failed to demonstrate prejudice or procedural unfairness, and the Council’s decision was neither arbitrary nor capricious (paras 43-44).