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 Town of Edgewood adopted ordinances approving the annexation of land within Bernalillo, Sandoval, and Santa Fe counties. The Santa Fe County Board of County Commissioners challenged one ordinance involving the annexation of 18,214 acres, arguing that the petition method used for annexation had technical deficiencies. The County claimed it had an interest in the annexed area due to its maintenance of public roads, asserting ownership through prescriptive easement or implied dedication (paras 2-3).
Procedural History
- District Court, Santa Fe County: Dismissed the County's appeal, holding that the County lacked standing under NMSA 1978, § 3-7-17(C), as it did not own land within the annexed territory (para 1).
Parties' Submissions
- Appellant (Santa Fe County Board of County Commissioners): Argued that its maintenance of public roads in the annexed area created title by prescription or common law implied dedication, satisfying the statutory requirement of "owning land" under NMSA 1978, § 3-7-17(C). The County also contended that the legislative purpose of the statute supported its standing (para 1).
- Respondent (Town of Edgewood): Asserted that the County's interest in maintaining public roads did not amount to "owning land" as required by the statute. It argued that the County's use interest was insufficient to confer standing (para 3).
- Intervenor (Campbell Farming Corporation): Supported the Town's position, arguing that even if a prescriptive easement existed, it did not satisfy the statutory ownership requirement (para 3).
Legal Issues
- Does the County's maintenance of public roads in the annexed area constitute "owning land" under NMSA 1978, § 3-7-17(C)?
- Does the County have standing to appeal the annexation ordinance under the statutory requirements?
Disposition
- The Court of Appeals affirmed the district court's dismissal of the County's appeal, holding that the County lacked standing under NMSA 1978, § 3-7-17(C) (para 14).
Reasons
Per Wechsler CJ (Sutin and Kennedy JJ. concurring):
The Court held that standing under NMSA 1978, § 3-7-17(C) requires equitable or legal fee title to real property within the annexed territory. The County's claimed interests, including prescriptive easement and implied dedication, were insufficient to meet this requirement (paras 1, 7).
The Court emphasized the plain meaning of "owning land," which entails having equitable or legal fee title, including the right to convey or exclude others. The County's use interest in maintaining public roads did not confer such ownership (paras 5-7).
The Court rejected the County's argument that "owning land" could include owning an interest in land, noting that such an interpretation would render the statutory language meaningless and undermine the legislature's intent to streamline the appeal process (paras 7-8).
The Court distinguished the case from State ex rel. State Highway & Transportation Department v. City of Sunland Park, where the Highway Department had equitable title under a specific statute. The County lacked a comparable statutory basis for its claim (paras 9-10).
Finally, the Court concluded that the County's interests, whether based on prescriptive easement or implied dedication, amounted only to a use interest and not ownership of land as required by the statute (paras 12-13).