District Court, D. New Mexico — appointed by Richard Nixon
Decision levers
AI-measured from their own opinions — each lever cites its cases
PurposivismTextualism
Yazzie v. Amigo Chevrolet applies the plain text of the Odometer Act and its regulations to find liability on uncontested facts without invoking broader purposes. Yazzie v. Amigo Chevrolet, Inc. ↗
Willing to revisit precedentStrong stare decisis
Southwest Center for Biological Diversity follows Tenth Circuit precedent from Forest Guardians to require timely agency compliance rather than revisiting it. Southwest Center for Biological … ↗
Deference to government powerSkepticism of government power
Middle Rio Grande Conservancy District invalidates the Secretary of the Interior's critical habitat rule for an inadequate record, showing willingness to check agency action under environmental statutes. Middle Rio Grande Conservancy Di… ↗
This case involved a lawsuit by the parents of student Joshua Butler against the City of Rio Rancho and Officer Russ Apgar, alleging violations of constitutional rights under 42 U.S.C. §§ 1983 and 1985 as well as state torts after Joshua was arrested and suspended for a year when a gun and knife were found in a car he had driven to school. The court granted summary judgment to the defendants on all claims against them, including conspiracy, false arrest, false imprisonment, malicious abuse of process, and punitive damages. It reasoned that Officer Apgar had probable cause to arrest Joshua without a warrant upon discovery of the weapons in the vehicle, rendering the arrest and related actions lawful under the Fourth Amendment and state law. The court noted that the weapons belonged to Joshua's brother and that school officials and the officer had observed a knife in plain view before searching further.
This case involves a civil rights lawsuit under 42 U.S.C. §§ 1983 and 1985 brought by parents on behalf of their son, a high school student suspended for one year after weapons were discovered in a borrowed car he drove to school, even though the hearing officer made no finding that he knowingly possessed them. The Rio Rancho Public School defendants moved to dismiss various counts of the complaint for failure to state a claim and sought reconsideration of an earlier denial of qualified immunity for individual defendants. The court granted the motion in part, dismissing Counts II, III, XII, XIV, XV, and XVIII, while allowing Counts VII, VIII, XVI, and XVII to proceed, and denied reconsideration of the qualified immunity ruling. The core reasoning was that the amended complaint alleged facts that could support a substantive due process violation because the suspension lacked a rational relationship to school discipline without a finding of scienter, and longstanding legal requirements for knowledge in such cases put defendants on notice that their actions might violate constitutional rights.
This case involves plaintiffs who purchased a used truck from defendant Amigo Chevrolet, a car dealership, and alleged that the dealer violated the federal Odometer Act by withholding the original title certificate (which included odometer disclosure from the prior owner) and instead using a power of attorney to obtain a new title, while also misrepresenting the truck's history. The court considered plaintiffs' motion for partial summary judgment based on uncontested facts showing the dealer intentionally concealed the title and transaction details. The court granted the motion, ruling that Amigo Chevrolet violated the Odometer Act and related regulations (49 U.S.C. § 32705 and 49 C.F.R. § 580) with intent to defraud by failing to properly disclose odometer information via the original title and by not retaining required records. The core reasoning was that federal regulations mandate use of the original title for odometer disclosure except in narrow circumstances not present here, and the dealer's knowing noncompliance plus efforts to conceal facts established liability as a matter of law without need to prove actual odometer tampering.
The consolidated cases challenge a 1999 final rule by the Secretary of the Interior designating critical habitat for the endangered Rio Grande silvery minnow along a 163-mile stretch of the Middle Rio Grande, brought by the Middle Rio Grande Conservancy District and the State of New Mexico under the Endangered Species Act, National Environmental Policy Act, Administrative Procedure Act, and the Fifth Amendment. Plaintiffs argued that the designation was arbitrary and capricious, that no Environmental Impact Statement was prepared despite significant effects on water use and agriculture, and that the administrative record was inadequate. On plenary review of the record, the court ruled for the plaintiffs, holding that the record failed to meet legal requirements and provided an insufficient basis for the Secretary's determinations or the final rule. The court later denied the government's motion for reconsideration or a stay of the order requiring a new designation.
This case involved an environmental advocacy group suing federal agencies under the Endangered Species Act to compel the redesignation of critical habitat for two threatened fish species, the spikedace and loach minnow, in Arizona and New Mexico after an earlier designation was invalidated for failing to comply with the National Environmental Policy Act. The court granted the plaintiffs' motion to compel agency action, denied the intervenor Phelps Dodge's request for discovery on standing issues, and ordered the U.S. Fish and Wildlife Service to complete and publish a final critical habitat determination by February 17, 2000. The court reasoned that the defendants had violated the ESA by delaying redesignation and that precedent from Forest Guardians v. Babbitt required timely compliance without allowing indefinite postponement based on resource allocation. It further held that the plaintiffs satisfied both constitutional and statutory standing requirements through a specific injury-in-fact tied to the species' protection under the ESA, rendering further discovery unnecessary.
This case involved taxpayers filing a quiet title action against the IRS to challenge the procedural validity of tax assessments, liens, and levies for years including 1980 through 1993, and to seek damages for alleged unlawful disclosure of confidential tax return information when notices were filed and published. The court ruled in favor of the United States on all claims, dismissing the case with prejudice after finding that the IRS had complied with all required notices and procedures under the Internal Revenue Code. The court reasoned that notices of deficiency and assessment sent to the plaintiffs were valid even when returned unopened, that liens and levies were lawful and enforceable, and that disclosures of tax information were authorized under exceptions for collection activities such as levies and sales. Plaintiffs did not contest the underlying tax liabilities but alleged only procedural defects, which the evidence failed to establish.