State ex rel. Angel Fire Home and Land Owners Association, Inc. v. South Central Colfax County Special Hospital District

797 P.2d 285 (1990)

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State ex rel. Angel Fire Home and Land Owners Association, Inc. v. South Central Colfax County Special Hospital District

New Mexico Court of Appeals
797 P.2d 285 (1990)

SC

Facts

New Mexico’s Special Hospital District Act (the act) permitted the creation of special hospital districts. The act required that the districts be compact and contiguous. If a district was to span more than one county, the act required the independent approval of the inhabitants of each county, each of which was called a subdistrict. Further, the act required that districts benefit their inhabitants. Finally, the act prohibited the creation of a district that would include an area already in a district. Pursuant to the act, the South Central Colfax County Special Hospital District (the district) (defendant) was created. The district encompassed multiple school districts within Colfax County, including Moreno Valley. Landowners in Moreno Valley (landowners) (plaintiffs) sued the district, claiming that the creation of the district was unconstitutional because it placed an unfair tax burden on them. Specifically, the landowners claimed that their community amounted to one-fourth of the population covered by the district but provided one-half of the tax base. Further, the landowners asserted that there was a hospital closer to them than the new district hospital would be, meaning that they would gain no benefit from the district. The district court ruled in the landowners’ favor, finding that the act was unconstitutional. The district appealed.

Rule of Law

Issue

Holding and Reasoning (Hartz, J.)

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