Price v. N.M. Soil & Water Conservation Comm'n

CourtNew Mexico Court of Appeals
DecidedOctober 31, 2022
StatusUnpublished

This text of Price v. N.M. Soil & Water Conservation Comm'n (Price v. N.M. Soil & Water Conservation Comm'n) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Price v. N.M. Soil & Water Conservation Comm'n, (N.M. Ct. App. 2022).

Opinion

The slip opinion is the first version of an opinion released by the Chief Clerk of the Supreme Court. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Chief Clerk for compliance with Rule 23-112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion.

1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

2 Opinion Number: _____________

3 Filing Date: October 31, 2022

4 No. A-1-CA-38176

5 GRANT W. PRICE,

6 Petitioner-Appellee,

7 v.

8 NEW MEXICO SOIL AND WATER 9 CONSERVATION COMMISSION, 10 including its Commissioners, DUSTON 11 HUNT a/k/a DUDLEY HUNT, J. STEVEN 12 GLASS, JOSE VARELA-LOPEZ, GABE 13 ESTRADA, JOHN NORRIS, and JOHN 14 SANCHEZ, JR. a/k/a CHARLIE SANCHEZ, 15 JR.,

16 Respondents-Appellants.

17 APPEAL FROM THE DISTRICT COURT OF DOÑA ANA COUNTY 18 James T. Martin, District Judge

19 Peter Goodman 20 Mesilla Park, NM

21 Michael W. Lilley 22 Las Cruces, NM

23 Sanders & Westbrook, PC 24 Maureen A. Sanders 25 Albuquerque, NM

26 for Appellee 1 Hector H. Balderas, Attorney General 2 Nicholas M. Sydow, Civil Appellate Chief 3 Amye Green, Assistant Attorney General 4 Santa Fe, NM

5 for Appellants 1 OPINION

2 YOHALEM, Judge.

3 {1} The question in this appeal is whether the constitutional principle of “one

4 person, one vote” 1 applies to the election of supervisors to a soil and water

5 conservation district’s board of supervisors, the governing body of the district. Soil

6 and water conservation districts are governmental entities created by the New

7 Mexico Soil and Water Conservation District Act (the Act), NMSA 1978, Sections

8 73-20-25 to -48 (1965, as amended through 2019), to encourage the conservation

9 and development of New Mexico’s soil, water, and natural resources.

10 {2} Petitioner Grant Price filed a petition for writ of mandamus in the district court

11 in 2017 objecting to the adoption of geographic voting zones with significantly

12 unequal population for the election of the Doña Ana County Soil and Water

13 Conservation District’s (the District) board of supervisors. Petitioner initially named

14 both the District and the Soil and Water Conservation Commission (the

15 Commission), which had approved the voting map drawn by the District, as

1 The “one person, one vote” requirement arises from the Equal Protection Clause of the United States Constitution. See Maestas v. Hall, 2012-NMSC-006, ¶ 1, 274 P.3d 66 (“The idea that every voter must be equal to every other voter when casting a ballot has its genesis in the Equal Protection Clause, U.S. Const. amend. XIV, § 1 (Equal Protection Clause), and is commonly referred to as the ‘one person, one vote’ doctrine.”). Plaintiff relies on both the United States Constitution and the New Mexico Constitution but draws no distinction on the applicable principles of law. We therefore refer solely to the principles of law developed under the United States Constitution. 1 Respondents. Petitioner complained that the voting zones as drawn violated the

2 United States Constitution’s “one person, one vote” requirement, diluting the voting

3 power of Petitioner and the other residents of Zone 4, the zone that includes the City

4 of Las Cruces. The district court agreed, finding that the District’s voting zones

5 “impermissibly dilute and diminish the voting rights of Zone 4 residents.” The

6 significantly unequal distribution of the population among the voting zones found

7 by the district court resulted, for example, in a single vote cast in Zone 3 having

8 nearly four times the weight of a vote cast in Zone 4.

9 {3} Based on these findings of fact, the district court concluded that the

10 Commission’s approval of the voting zones was not authorized by the Legislature,

11 was inconsistent with the Commission’s statutory duty under Section 73-20-39 of

12 the Act to ensure proper and equitable representation of district voters, and was in

13 violation of the “one person, one vote” mandate of the United States Constitution as

14 well.

15 {4} We agree that Section 73-20-39 does not authorize the adoption of geographic

16 voting zones for the election of district supervisors, which deviate from the “one

17 person, one vote” requirement of the Equal Protection Clause. We therefore affirm

18 the district court’s grant of a writ of mandamus requiring the Commission to “rescind

19 its approval for the current geographic [electoral] zones within the . . . District.”

2 1 BACKGROUND

2 I. The Soil and Water Conservation District Act

3 {5} The Act was enacted by our Legislature in 1965. The Act creates a state

4 Commission charged with overseeing the creation of soil and water conservation

5 districts throughout the state. See §§ 73-20-28, -33. The stated purpose of the Act,

6 and the task assigned to the Commission and the districts, is to encourage and help

7 execute “appropriate corrective and conservation practices and programs,” § 73-20-

8 26(A)(3), and to “conserve and develop beneficially the soil, water and other natural

9 resources of the state,” id., so as to “promote the health and general welfare of the

10 people of the state,” § 73-20-26(A)(1). Under the terms of the Act, the districts and

11 the Commission focus on preventing flooding and soil erosion, remediating excess

12 deposits of sediment, as well as on the conservation, beneficial application, and

13 development of water resources.

14 {6} The Act provides a process for the creation of districts throughout the state.

15 See § 73-20-33 (specifying the process for creating a district and determining the

16 boundaries of that district). Sections 73-20-26(B) and 73-20-44(A) provide that a

17 soil and water conservation district organized under the Act “is a governmental

18 subdivision of the state, a public body politic and corporate,” distinct from the

19 Commission. The process of creating a district is initiated by a request to the

20 Commission from a group of at least twenty-five landowners in the proposed district.

3 1 See § 73-20-33(A). The landowners propose geographic boundaries for the new

2 district, which the Commission reviews, and approves or rejects. Id. If the district

3 and its boundaries are approved by the Commission, there is a district-wide vote of

4 registered voters residing within the district boundaries. See § 73-20-33(A)(4). The

5 creation of the district requires the approval of the majority of those voters. See

6 §§ 73-20-33(A)(4)(b),(c), -34. Since 1965, when the Act became law, forty seven

7 soil and water conservation districts have been created.

8 {7} The governing body of each district is composed of between five and seven

9 supervisors. See § 73-20-37(A). Five are elected in accordance with the Local

10 Election Act, NMSA 1978, § 1-22-1 to -19 (1985, as amended through 2019). See

11 § 73-20-37(A). The Commission is allowed to appoint up to two additional

12 supervisors. See id. Of the five elected supervisors, four are required to be

13 landowners within the geographical area of the district. Id. The fifth supervisor need

14 not meet the landowner qualification. Id.

15 {8} The Commission is empowered by Section 73-20-39 to adopt rules for the

16 election of the board of supervisors in each district. Of central importance to this

17 case, Section 73-20-39 authorizes the Commission to approve geographic voting

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Price v. N.M. Soil & Water Conservation Comm'n, Counsel Stack Legal Research, https://law.counselstack.com/opinion/price-v-nm-soil-water-conservation-commn-nmctapp-2022.