Court: New Mexico Supreme Court; March 6, 1956; New Mexico; State Supreme Court
The plaintiffs, B. M. Mayfield and Deane F. Stahmann (Trustee), appealed a judgment from the Dona Ana County district court that denied their claims for refunds of charges paid for "excess water" used for irrigation during 1948 and 1949. Elephant Butte Irrigation District, a New Mexico corporation formed under federal reclamation laws, delivered water from the Rio Grande, classifying any quantity over one acre-foot as "excess water."
In 1948, Mayfield was charged $771.10 for 439 acre-feet of excess water, while Stahmann was charged $26,270.00 for 15,700 acre-feet. In 1949, the charges escalated based on a tiered pricing structure, with Mayfield paying $332.20 for 374 acre-feet and Stahmann $16,726.00 for 16,590 acre-feet. Both plaintiffs paid these charges under protest in early 1949 and 1950.
The court found that Mayfield did not receive or was charged for more than three acre-feet of water in 1949 and that the irrigation district used the best available and accurate measuring techniques for water delivery. The water supplied to the plaintiffs was also delivered by the Bureau of Reclamation. The findings from the trial court were incorporated into its decision.
Water was delivered to the Plaintiffs' lands under a written contract with the District. The Plaintiffs received annual notices on November 1st regarding their water charges, which were due February 1 of the following year, along with monthly statements during the irrigation season. In 1948, water availability for irrigation was significantly below normal, leading to shortages. The average water consumption for normal crop production in the District is three acre-feet per acre, with the irrigation season typically starting around March 1.
Under a 1937 contract between the Elephant Butte Irrigation District and the Department of the Interior, the Secretary of the Interior provides estimated operation and maintenance costs by September 1 each year. If these estimates are deemed insufficient, the Secretary must notify the District of the deficiency, which must be paid within 15 days; failure to do so releases the United States from any obligation to deliver water beyond available funds.
Plaintiffs' counsel argue that New Mexico district courts have jurisdiction over irrigation districts formed under state laws in cooperation with federal reclamation laws, a point not contested by the defendant's counsel. However, the defendant contends that the district court lacks authority to grant refunds due to untimely filings and insufficient claims. Additionally, Plaintiffs assert that the defendant unlawfully assesses and collects graduated tolls for water delivered beyond a minimum assessment, arguing these charges do not correlate with the actual delivery costs or benefits received by users and do not aim to conserve water.
The enabling statute for irrigation districts outlines the financial responsibilities and processes for managing irrigation systems. It allows the board of directors to set rates for tolls and charges for users of the canals and water, as well as to levy assessments to cover operational costs, maintenance, and improvements. These assessments must constitute between one-fourth and two-thirds of the estimated operation and maintenance expenses for the upcoming year and apply to all lands within the district, except those specifically exempted by the statute. Users of the irrigation systems are required to submit a written statement detailing the number of acres to be irrigated and the intended crops when applying for water. The board is tasked with estimating the needed funds annually and ensuring that both tolls and assessments are collected to meet the district's financial obligations, including payments to the United States for water rental.
The board is required to estimate the necessary funds for the district by July 1st each year, including amounts for any unpaid obligations. This estimate must cover at least one-fourth to two-thirds of the operational and maintenance costs for the irrigation and drainage systems, as specified in section 5 of the act. The funds will be collected from all lands in the district, with certain exemptions, while users of the systems will pay the remainder according to their water contracts. The federal government provides an annual estimate of charges for operation and management, which must be paid promptly. If the Secretary of the Interior finds that this estimate is insufficient, the district must pay any deficiency within 15 days, or risk losing water delivery. The plaintiffs argue that the district lacks authority to levy assessments exceeding the minimum charge for water unless they relate to costs or benefits. They acknowledge there is no statute mandating that excess charges be based on delivery costs but contend it is a fair approach. They concede that the board has discretion in setting charges but claim it has been abused, despite no allegations of discrimination or fraud. The trial judge ruled that the court lacked authority to intervene in the board's management, leading to the dismissal of the complaints. The decision is supported by prior case law regarding the board's powers.
The Sperry case, while not identical to the current situation, involves the district court's authority to intervene in the board's management of internal district affairs, particularly regarding assessments. Key statutory provisions cited by appellants include one mandating the board to meet annually to determine necessary funds and another requiring inclusion of contract payment amounts in any levy or assessment. Appellants argue that these provisions restrict the board's estimates and tax levies to only those amounts that can be definitively shown as required for disbursement in the coming year. They contend that the board's opinion regarding probable disbursements is insufficient. The court, however, expresses skepticism about the practicality of imposing such strict requirements, suggesting that it could hinder the district's operations under constant scrutiny from landowners or court mandates. The court emphasizes the broad discretionary powers granted to the board, indicating that a strict interpretation akin to municipal corporation powers is not warranted. Numerous precedents, including cases like Crawford v. Imperial Irrigation Dist. and Wiggs v. City of Albuquerque, support the principle of judicial non-interference in matters within the discretion of municipal bodies. The defendant references additional case law from other states that align with the trial court's findings, specifically addressing the legality and reasonableness of assessments and the structure of rates for water usage by landowners.
The board of correction's review of assessments for maintenance and operation is deemed final and conclusive unless there is evidence of fraud or intentional discrimination akin to fraud, neither of which was demonstrated in this case. The court upheld the district court's decision denying the appellants' claim for refund of alleged excess payments. It ruled that the validity of assessments for excess water usage does not depend on explicitly stated reasons, such as costs or benefits, as other justifications could exist in the minds of the board members, such as addressing prior deficiencies in federal charges. The broad powers granted to the board in managing the district's fiscal policies support the trial court's decision against challenges to the assessments. Additionally, the defendant argued that the plaintiffs' claims for refunds were not filed in a timely manner, but the court found it unnecessary to address this defense due to the conclusions reached. Ultimately, the judgment of the trial court was affirmed.
