Tobin Dolan; Lydia Dolan; Tangee Dolan; Dorothy Jones; Brian Rodgers; Barbara Rodgers; Michael Salazar; Reynaldo Herrera; and Kathy Valera v. Federal Emergency Management Agency; Marianna Lands and Charles William Paynter v. Federal Emergency Management Agency; Deanne Criswell, as Administrator of FEMA; and Angela Gladwell

CourtDistrict Court, D. New Mexico
DecidedJanuary 8, 2026
Docket1:23-cv-00869
StatusUnknown

This text of Tobin Dolan; Lydia Dolan; Tangee Dolan; Dorothy Jones; Brian Rodgers; Barbara Rodgers; Michael Salazar; Reynaldo Herrera; and Kathy Valera v. Federal Emergency Management Agency; Marianna Lands and Charles William Paynter v. Federal Emergency Management Agency; Deanne Criswell, as Administrator of FEMA; and Angela Gladwell (Tobin Dolan; Lydia Dolan; Tangee Dolan; Dorothy Jones; Brian Rodgers; Barbara Rodgers; Michael Salazar; Reynaldo Herrera; and Kathy Valera v. Federal Emergency Management Agency; Marianna Lands and Charles William Paynter v. Federal Emergency Management Agency; Deanne Criswell, as Administrator of FEMA; and Angela Gladwell) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tobin Dolan; Lydia Dolan; Tangee Dolan; Dorothy Jones; Brian Rodgers; Barbara Rodgers; Michael Salazar; Reynaldo Herrera; and Kathy Valera v. Federal Emergency Management Agency; Marianna Lands and Charles William Paynter v. Federal Emergency Management Agency; Deanne Criswell, as Administrator of FEMA; and Angela Gladwell, (D.N.M. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO

TOBIN DOLAN; LYDIA DOLAN; TANGEE DOLAN; DOROTHY JONES; BRIAN RODGERS; BARBARA RODGERS; MICHAEL SALAZAR; REYNALDO HERRERA; and KATHY VALERA,

Plaintiffs,

vs. No. CIV 23-0908 JB/JFR

FEDERAL EMERGENCY MANAGEMENT AGENCY,

Defendant.

-- and --

MARIANNA LANDS and CHARLES WILLIAM PAYNTER;

vs. No. CIV 23-0869 JB/JFR

FEDERAL EMERGENCY MANAGEMENT AGENCY; DEANNE CRISWELL, as Administrator of FEMA; and ANGELA GLADWELL,

Defendants.

MEMORANDUM OPINION AND ORDER

THIS MATTER comes before the Court on the Defendants/Respondents’ Motion to Stay Judgments Pending Appeal, filed September 16, 2025 (Doc. 87)(“Motion to Stay”). The Court holds a hearing on December 18, 2025. See Clerk’s Minutes at 1, filed December 18, 2025 (Doc. 118). The primary issues are: (i) whether the Court must automatically stay the Final Judgment, filed December 31, 2024 (Doc. 61)(“Final Judgment”) pending appeal under rule 62(b) of the Federal Rules of Civil Procedure, because the Final Judgment operates as a money judgment, given that it compels FEMA to award noneconomic damages for injuries resulting from the Hermit’s Peak/Calf Canyon Fire; and (ii) whether the Court should exercise its discretion to stay the judgments under rule 62(d), because the discretionary stay factors favor Defendant Federal

Emergency Management Agency (“FEMA”). The Court concludes that: (i) an automatic stay is unavailable, because the Final Judgment does not operate as money judgment, given that it does not require payment of any specific dollar amount to any individual claimant; and (ii) a discretionary stay is unwarranted, because the stay factors favor the Plaintiffs. Because the Final Judgment mandates compliance rather than compensation -- and because the equities do not justify delay -- a stay has no place here. FACTUAL BACKGROUND In April 2022, a wildfire scorched over 340,000 acres of land in northeastern New Mexico, destroying over 900 structures, and forcing the evacuation of over 15,000 households throughout Mora, San Miguel and Taos Counties. See Patrick Lohmann, Were You Affected by the Massive

Wildfire in Northern New Mexico? We Want to Hear From You, Were You Affected by the Massive Wildfire in Northern New Mexico? We Want to Hear From You (March 2, 2023), https://www.propublica.org/getinvolved/new-mexico-wildfires-hermits-peak-calf-canyon (last accessed December 30, 2025). It is the largest wildfire in New Mexico State history. See Bryan Pietsch and Jason Samenow, New Mexico blaze is now largest wildfire in state history, The Washington Post (May 17, 2022), https://www.washingtonpost.com/nation/2022/05/17/calf- canyon-hermits-peak-fire-new-mexico/ (last accessed December 30, 2025). The first wildfire began on April 6, 2022, in Hermit’s Peak, New Mexico, when the United States Forest Service (“Forest Service”) initiates a prescribed burn in the Santa Fe National Forest in San Miguel County that quickly spreads beyond federal land and turns into a wildfire. See Hermit’s Peak Act § 102(a) Findings and Purposes, 136 Stat. 2144, 2168 (“Hermit’s Peak Act § 102(a)”). A second wildfire begins on April 19, 2022, in Calf Canyon, New Mexico, when a dormant pile burn1 from the prior winter re-emerges. See Hermit’s Peak Act § 102(a). Within the same month, on April 27, 2022,

the wildfires at Hermit’s Peak and Calf Canyon merge, and form the Hermit’s Peak/Calf Canyon Fire. See Hermit’s Peak Act § 102(a). By May 2022, the Hermit’s Peak/Calf Canyon Fire caused evacuations in multiple villages and communities, including San Miguel County jail, the State’s psychiatric hospital, the United World College, and New Mexico Highlands University. See Hermit’s Peak Act § 102(a). At the request of New Mexico Governor Michelle Lujan Grisham, President Joe Biden issues a major disaster declaration for the counties of Colfax, Mora, and San Miguel. See Hermit’s Peak Act § 102(a); Hermit’s Peak/Calf Canyon Fire Assistance, 88 Fed. Reg. 33808 (August 29, 2023)(codified at 44 C.F.R. 296). The Forest Service fully contains the Hermit’s Peak/Calf Canyon Fire four months later, in August 2022. See The New Mexican, Hermits Peak/Calf Canyon Fire 100 percent contained, fire officials say (August 21, 2022),

https://www.santafenewmexican.com/news/local_news/hermits-peak-calf-canyon-fire-100- percent-contained-fire-officials-say/article_5ac054fc-21a1-11ed-9401-134e852ee0a8.html (last visited December 30, 2025). The Forest Service assumes responsibility for the Hermit’s Peak/Calf Canyon Fire. See Hermit’s Peak Act § 102(a). In September 2022, Congress establishes a dedicated relief fund to compensate victims of the Hermit’s Peak/Calf Canyon Fire by enacting the Hermit’s Peak Act. See Hermit’s Peak Act §

1A pile burn “is a type of prescribed fire where firefighters pile and burn forest debris to reduce an area’s wildfire risk.” Pile Burning, United States Forest Service, https://www.fs.usda.gov/detail/arp/landmanagement/resourcemanagement/?cid=fsm91_058291 (last accessed December 30, 2025). 102(b), 136 Stat. at 2169 (“§ 102(b)”). The Hermit’s Peak Act has two purposes: “(1) to compensate the victims of the Hermit’s Peak/Calf Canyon Fire, for injuries resulting from the fire; and (2) to provide for the expeditious consideration and settlement of claims for those injuries.” Hermit’s Peak Act § 102(b). The Hermit’s Peak Act defines injury using the Federal Tort Claim

Act’s definition, which is “injury or loss of property or personal injury or death.” Hermit’s Peak Act § 103(5), 136 Stat. at 2169 (citing FTCA 28 U.S.C. § 1346(b)(1)). The Hermit’s Peak Act also directs FEMA’s Administrator to promulgate regulations for the processing and payment of claims. See Hermit’s Peak Act § 104(f)(1). FEMA publishes its final regulations on August 29, 2023. See 44 C.F.R. § 296 (“Hermit’s Peak Regulations”). The Hermit’s Peak Regulations state that the purpose of the Hermit’s Peak Act is to “receive, evaluate, process, and pay actual compensatory damages for injuries resulting from the Hermit’s Peak/Calf Canyon Fire.” 44 C.F.R § 296.1. To receive compensation, a claimant “must be an Injured Person who suffered injury as a result of the Hermit’s Peak/Calf Canyon Fire and sustained damages.” 44 C.F.R. § 296.20. First, a claimant must file a Notice of

Loss form with the FEMA Claims Office that briefly describes each injury. See 44 C.F.R. § 296.5(b); id § 296.10(a). Second, a Claims Reviewer reviews and evaluates the claim. See 44 C.F.R. § 296.5(c). Third, an Authorized Official2 determines whether FEMA owes compensation to the claimant. See 44 C.F.R. § 296.5(d). Furthermore, acceptance of an award under the Hermit’s Peak Act bars recovery under the Federal Tort Claims Act or a civil action against the United States regarding the same subject matter. See 44 C.F.R. § 296.5(a).

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Tobin Dolan; Lydia Dolan; Tangee Dolan; Dorothy Jones; Brian Rodgers; Barbara Rodgers; Michael Salazar; Reynaldo Herrera; and Kathy Valera v. Federal Emergency Management Agency; Marianna Lands and Charles William Paynter v. Federal Emergency Management Agency; Deanne Criswell, as Administrator of FEMA; and Angela Gladwell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tobin-dolan-lydia-dolan-tangee-dolan-dorothy-jones-brian-rodgers-nmd-2026.