State ex rel. Haynes v. Bonem

N.M. Const. art. X, § 6 was known as the home-rule amendment. Under the amendment, a municipality that adopted a home-rule charter was granted broad authority over matters of local concern. The city of Clovis (the city) (defendant) adopted such a charter and became a home-rule municipality. The city commission was composed of eight members elected from four dual-member districts. While the city was considering various redistricting plans, Allan Haynes (plaintiff) proposed changing the composition of the commission to five members elected from five single-member districts. Haynes’s proposal was based on two New Mexico state statutes. The first was N.M. Stat. Ann. § 3-10-1(B), which stated that a city commission must have five members. The second was N.M. Stat. Ann. § 3-14-6(A), which stated that commission members had to be elected from five single-member districts. The city refused Haynes’s proposal and instead adopted a plan that retained four dual-member districts. Haynes subsequently filed a petition for a writ of mandamus, seeking to compel the city to adopt a plan providing for five single-member districts. The district court rejected Haynes’s petition for mandamus. Haynes petitioned the New Mexico Supreme Court for a writ of prohibition, requesting that the supreme court issue a writ prohibiting the district court from dismissing the petition for mandamus. The supreme court issued an alternative writ of prohibition and agreed to hear the case.