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 Petitioner, an inmate serving a life sentence plus seven and a half years for murder, submitted several requests for records to prepare for a disciplinary hearing after being placed in solitary confinement for possession of contraband. These requests were made using internal forms provided by the New Mexico Corrections Department (NMCD) and were not explicitly identified as requests under the Inspection of Public Records Act (IPRA) (paras 2-5).
Procedural History
- District Court, July 2023: Denied the petition for a writ of mandamus to enforce IPRA, finding that the requests were governed by NMCD internal policies and not IPRA (para 8).
Parties' Submissions
- Petitioner-Appellant: Argued that his requests for records should be considered under IPRA, entitling him to the requested documents and statutory damages (para 9).
- Respondents-Appellees: Contended that the requests did not trigger IPRA obligations as they were made on internal forms for specific purposes and not submitted to the designated records custodian (para 9).
Legal Issues
- Whether the Petitioner’s requests made on internal NMCD forms equate to public records requests under IPRA (para 11).
Disposition
- The Court of Appeals affirmed the district court's decision, denying the petition for a writ of mandamus (para 15).
Reasons
Per Medina J. (Duffy and Yohalem JJ. concurring): The Court found that the Petitioner’s requests did not trigger IPRA because they were made using NMCD internal forms without any reference to IPRA or public records. The forms were intended for document reviews and legal access under NMCD policies, not public records requests. The Court emphasized that IPRA requests must be reasonably identified as such and submitted to the designated records custodian. Since the Petitioner did not follow these procedures, NMCD officials had no duty to comply with IPRA, and mandamus was not appropriate (paras 10-14).