STATE OF NEW MEXICO

COUNTY OF SANTA FE

FIRST JUDICIAL DISTRICT COURT

 

NEW MEXICANS FOR FREE ENTERPRISE,

THE SANTA FE CHAMBER OF COMMERCE,

MARK KIFFIN, MARK C. MILLER,

PRANZO, ZUMA CORPORATION,

ROBBIE DAY, and PINON GRILL AT

THE HILTON OF SANTA FE,

 

                                                Plaintiffs,

 

v.                                                                                 No. D-101-CV-2003-00468

 

THE CITY OF SANTA FE,

 

                                                Defendant.

             

 

 

CITY’S REPLY TO PLAINTIFFS’ RESPONSE TO THE

CITY OF SANTA FE’S MOTION FOR SUMMARY JUDGMENT

 

PRELIMINARY STATEMENT

Plaintiffs respond to the City of Santa Fe’s Motion for Summary Judgment (the “Moving Brief” or “Mov. Br.”) by simply ignoring the controlling authority which overwhelmingly confirms the validity of the Living Wage Ordinance (the “Ordinance”) establishing a city-wide minimum wage that addresses the special needs and conditions of the Santa Fe community.

It cannot be disputed that the New Mexico Legislature has expressly conferred on the City the power to adopt ordinances for the purpose of “providing for the safety, preserving the health, promoting the prosperity and improving the morals, order, comfort and convenience of the municipality and its inhabitants.”  Section 3-17-1 NMSA 1978.  The Legislature has also conferred on the City the power to regulate businesses if it is “conducive to promotion of the health and general welfare of the municipality.”  Section 3-38-1 NMSA 1978.

It is also undisputed that even if an ordinance were considered a law governing “civil relationships” within the meaning of Article X, § 6(D) of the New Mexico Constitution, the restriction on  such ordinances expressly does not apply to ordinances enacted “incident to the exercise of an independent municipal power.”  Plaintiffs recognize that an ordinance is incident to an independent municipal power “if it protects the health, safety and welfare of its inhabitants.”  Plaintiffs’ Response to City of Santa Fe’s Motion for Summary Judgment (“Plaintiffs’ Response” or “Pl. Resp.”) 17.  Incredibly, however, Plaintiffs argue that the Ordinance establishing a minimum wage for Santa Fe is not an exercise of the power to protect health, safety and welfare.  This argument ignores, indeed never even mentions, more than 60 years of state and federal jurisprudence establishing that minimum wage laws are a classic exercise of such power.

Plaintiffs take a similar approach in their arguments that the Ordinance violates the Equal Protection and Due Process clauses.  Here, they ignore the long-accepted principle that such challenges to minimum wage laws and other social and economic legislation are reviewed using the deferential “rational basis” standard, which requires courts to uphold legislation if any rational basis for the law’s enactment, or the classifications included within it, can be discerned or even imagined. Under this principle, courts are forbidden from second-guessing the wisdom or factual support for policies and distinctions adopted by the legislative body.  Plaintiffs, without citing a single supporting authority, assert that Santa Fe’s minimum wage ordinance is subject to “strict scrutiny”—reserved for laws such as those discriminating on the basis of race or restricting fundamental rights like free speech—and invite this Court to substitute its own judgment for that of the Santa Fe City Council.  There is no basis for Plaintiffs’ assertion. 

  Plaintiffs’ argument that the Ordinance is preempted by the New Mexico Minimum Wage Act (“MWA”) is equally without merit.  Plaintiffs admit that under the New Mexico Constitution, municipalities have all legislative power “not expressly denied by general law.”  Art. X, § 6(D).  But they can point to no language in the MWA constituting an express denial of a city’s power to adopt a local minimum wage.  In the absence of such an express denial, preemption will be found only where there is a clear conflict between the ordinance and the state law at issue.  Plaintiffs simply ignore the well-established principle of New Mexico law that mere differences between a New Mexico statute and a municipal ordinance do not establish such a conflict, where—as here—the municipal ordinance complements or imposes stricter standards than the statute and where compliance with the ordinance does not prevent compliance with the statute.  Here, as the City has shown, the Ordinance merely complements the MWA and compliance with the City’s higher minimum wage standards in no way prevents compliance with the MWA. 

Plaintiffs’ argument that the Ordinance conflicts with New Mexico’s antitrust law is simply nonsense.  It flies in the face of the United States Supreme Court’s common-sense holding—interpreting identical provisions of the federal antitrust laws—that a municipality’s unilateral imposition of regulatory requirements cannot violate the antitrust laws.  See Fisher v. City of Berkeley, 475 U.S. 260, 266 (1986); Mov. Br. 53-54.  Plaintiffs attempt to avoid the controlling principle of Fisher by misreading it.

Plaintiffs’ final argument that the Ordinance conflicts with Eminent Domain Law and is an unconstitutional taking is frivolous.  It ignores unanimous authority that laws do not involve a taking merely because compliance requires the payment of money.  Plaintiffs’ contention to the contrary would render invalid virtually every law that requires businesses to spend money to meet health, safety, environmental and other regulatory requirements.     

STATEMENT OF UNDISPUTED MATERIAL FACTS

It is plain that there are no material disputed issues of fact and that this motion for summary judgment presents pure questions of law.

Plaintiffs admit virtually all of the Undisputed Material Facts set forth by the City, as they must.  See Pl. Resp. ¶ 1 (admitting ¶ 1, 2, 3, 6, 7, 8, 9, 10, 13, 14, 15, 16, 18, 19, 21, 22, 27, 28, 29 and 30 of the City’s Statement).  The City provided a detailed legislative history of the Ordinance solely to show the lengthy, open democratic process that led to its enactment and the economic and social debate about the wisdom of the Ordinance, which the City ultimately resolved in favor of the Ordinance by a 7-to-1 vote.  This history was not offered as an invitation to the Court to second guess the City Council’s resolution of that debate—which the Court may not do under established principles of New Mexico and federal law—but simply so the Court could understand the rational basis for the City Council’s legislative enactment.  See Mov. Br. 35-37.

Although Plaintiffs purport to dispute a handful of the items in the City’s Statement, on examination these “disputes” turn out to be mere semantic quibbles.  Compare Mov. Br. ¶¶ 4, 5, 11, 12, 17, 20, 23, 24, 25, 26, 31 with Pl. Resp. ¶¶ 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12.  There simply are no genuine disputes over any material facts set forth by the City. 

Paragraphs 21, 22, 23, 24, 25, 26, 28, 29, 30, and 31 of Plaintiffs’ Statement of Undisputed Material Facts are in fact the subject of dispute as shown in the legislative record, but they are not material as a matter of law to the issues before the Court.  These disputes concern the wisdom, policy and judgments of the legislators in adopting the Ordinance to protect the health, safety and welfare of the citizens of Santa Fe, which are not subject to resolution by the Court.  See Mov. Br. 35-37.  The two expert reports offered by Plaintiffs simply make policy arguments against the Ordinance—policy arguments that the City Council considered[1] and evidently found unpersuasive compared to the substantial body of economic analysis favoring the Ordinance.  Moreover, the report of Dr. MacPherson does not even address the version of the Ordinance actually adopted.  It addresses earlier versions with different timetables for increases in the minimum wage, different exemptions and, most importantly, a different cutoff (10 employees instead of 25 employees) for the small business exemption.  Plaintiffs in a footnote state that these fundamental changes do not affect Dr. MacPherson’s report, but provide no reasons or evidence to support that proposition.  See Pl. Resp. 6 n 1. 

The assertions in paragraphs 14-18 of Plaintiffs’ Statement of Undisputed Material Facts purportedly showing economic hardships to certain plaintiffs are immaterial as a matter of law because they go only to the policy merits of the Ordinance which may not be considered.  In any event, these “facts” should not be considered because Plaintiffs have submitted no admissible evidence supporting them.  See Rule 1-056(E) NMRA 1998.  Plaintiffs have submitted conclusory affidavits stating baldly that certain individual Plaintiffs anticipated or experienced certain rates of return and that as a result of the Ordinance, they will experience substantially lower or negative returns.  See Pl. Resp., Exhibits 2, 3, 4, 5.  Each of them recites that these conclusions are based on an increase in the minimum wage to $10.50 per hour, something that will not occur until 2008.  The affidavits do not describe Plaintiffs’ factual basis or methodology for calculating “rates of return,” what assumptions were used concerning the number of employees who would have their wages increased and by how much, or what prices these Plaintiffs would or could charge for their products or services to cover the wage increases thereby eliminating or substantially mitigating any economic hardship.  Without such information, Plaintiffs’ assertions are worthless.  The statement of the national average return for restaurants in paragraph 19 of Plaintiffs’ Statement is similarly immaterial and also inadmissible because it is based on a conclusory assertion of an accountant without any back up and without any indication of its source.  See Pl. Resp. 5, Exhibit 6.

 

ARGUMENT

I.                   THE ORDINANCE IS WELL WITHIN THE BROAD AUTHORITY GRANTED TO SANTA FE BY THE NEW MEXICO CONSTITUTION AND NEW MEXICO STATUTORY LAW

Plaintiffs’ main argument is that the Ordinance is invalid because it is a law “governing civil relationships” under the New Mexico Constitution, which provides:

A municipality which adopts a charter may exercise all legislative powers and perform all functions not expressly denied by general law or charter.  This grant of powers shall not include the power to enact private or civil laws governing civil relationships except as incident to an independent municipal power. 

Article X, §6(D). 

As discussed below, the City submits that an ordinance regulating minimum wages does not govern “civil relationships” within the meaning of the New Mexico Constitution.  As pointed out in the City’s Moving Brief, however, the Court need not address this issue—one of first impression—because, even if the Ordinance were a “law governing civil relationships,” the Ordinance so clearly falls within the exception in Article X, §6(D) for “laws enacted incident to an independent municipal power.”  We therefore first address the simpler issue:  whether a minimum wage law such as the Ordinance falls within the Article X exception because it was enacted pursuant to the City’s independent power to promote the “health, safety and welfare” of its inhabitants.     

A.                 The Ordinance Was Enacted Incident To Santa Fe’s Exercise Of Its Independent Municipal Powers Granted To It By The New Mexico Legislature

As discussed in the City’s Moving Brief (19-23), the New Mexico Legislature has made three grants of independent power to its municipalities that are relevant here:

 

·        Section 3-17-1 NMSA 1978:  municipalities have the power to “adopt ordinances not inconsistent with the laws of New Mexico for the purpose of . . . providing for the safety, preserving the health, promoting the prosperity and improving the morals, order, comfort and convenience of the municipality and its inhabitants.”

 

·        Section 3-18-1 NMSA 1978:  municipalities may “preserve the peace and order within the municipality.”

 

·        Section 3-38-1 NMSA 1978:  municipalities may regulate businesses if “conducive to the promotion of the health and general welfare of the municipality.”

The Ordinance was enacted pursuant to these independent powers granted to municipalities by the New Mexico Legislature.[2]

Plaintiffs agree that an ordinance is “‘incident to the exercise of an independent municipal power’ if it protects the health, safety and welfare of its inhabitants.” Pl. Resp. 17.  They argue, however, that “Health, Safety, and Welfare” do not include the power to impose a minimum wage. Pl. Resp. 17-18.  This is absurd.  Since 1937, the United States Supreme Court and state and federal courts throughout the country have held that setting a minimum wage is a classic exercise of a government’s power to promote the health, safety and welfare.  See Mov. Br. 21-22; West Coast Hotel v. Parrish, 300 U.S. 379, 392-93 (1937); see also Siuslaw Concrete Constr. Co. v. Washington Dep’t of Transp., 784 F.2d 952, 958 (9th Cir. 1986); La. Assoc. General Contr., Inc. v. Calcaieu Parish  School Board, 586 So. 2d 1354, 1366 (La. 1991); Baltimore v. Sitnick, 255 A.2d 376, 378-79 (Md. 1969).  The Ordinance, which enacts a minimum wage for Santa Fe workers, therefore falls squarely within the power conferred on municipalities by the New Mexico Legislature to enact ordinances to promote the health, safety and welfare.

Plaintiffs cite no case holding that a minimum wage law is not a valid exercise of the health, safety and welfare power.  Moreover, none of the cases cited by Plaintiffs addresses the issue of whether a minimum wage law falls within the exception found in Article X, § 6(D) of the New Mexico Constitution or similar provisions in other state constitutions. 

The only case cited by Plaintiffs that they claim addresses a minimum wage law in the context of such a constitutional provision is New Orleans Campaign for a Living Wage v. City of New Orleans, 825 So. 2d 1098 (La. 2002).  See Pl. Resp. 12.  That case, however, did not address either the issue of whether a minimum wage law was a law “governing civil relationships” or the issue of whether it fit within the exception for laws enacted “incident to an independent municipal power.”  In City of New Orleans the case turned entirely on a statute enacted by the Louisiana Legislature—similar to the one Plaintiffs and their supporters unsuccessfully lobbied for in the New Mexico Legislature—specifically prohibiting Louisiana municipalities from “establishing a minimum wage rate which a private employer would be required to pay employees.”  Id. at 1100.  The Louisiana Supreme Court expressly stated that because of the existence of this statute, it would not address the Louisiana constitutional provision “which states that no local governmental subdivision shall, except as provided by law, enact an ordinance governing civil or private relationships.”  Id. at 1108. 

Plaintiffs misleadingly cite to a concurring opinion in the City of New Orleans case, arguing that “the contract of labor between an employer and employee is a private and civil relationship.”  Id. at 1108; see also Pl. Resp. 12.  Notably, the concurring opinion of another judge makes the point that the exception found in the Model State Constitution (that was adopted verbatim in Article X, § 6(D) of the New Mexico Constitution) and the exception in the Louisiana Constitution differed and that the Louisiana exception was narrower than the exception in the Model (and therefore also narrower than the exception in New Mexico’s Article X, § 6(D)).  See id. at 1119; see also Jefferson B. Fordham, Am. Mun. Ass'n, Model Constitutional Provisions for Municipal Home Rule (6th ed. 1968); Nat'l Mun. League, Model State Constitution (1958).  Thus, the City of New Orleans case provides no support for Plaintiffs’ position.

Plaintiffs also rely heavily on Bloomington v. Chuckney, 331 N.E.2d 780 (Ind. App. 1975).  That case, however, did not involve a minimum wage ordinance.  In Chuckney, the Indiana Supreme Court examined a local landlord-tenant law that attempted to redefine completely the landlord-tenant relationship with a complex ordinance entitled “An Act to Improve the Quality of Housing In the City of Bloomington.”  Id. at 781.  This ordinance was based largely on the Uniform Landlord and Tenant Act drafted by the Commissioners on Uniform State Laws.  See id. at 782.  The Court found that this landlord-tenant code was a law governing civil relationships and was not enacted pursuant to an independent municipal power.  See id. at 784.  The Chuckney court found that the ordinance dramatically redefined the landlord-tenant relationship and applied to aspects of that relationship wholly unrelated to the safety concerns cited by the city.  Hence, it held that the city had exceeded the health, safety and welfare power conferred on it by the Indiana Constitution and statutes.  See id.  The Santa Fe Ordinance, however, does not reorder or redefine the relationship between employer and employee.  It merely establishes the minimum wage that employers must pay in light of the special economic circumstances and living conditions in Santa Fe.  As such, it is the type of law long recognized as a proper exercise of the power to promote the health, safety and welfare of the community.

Plaintiffs also rely on a Massachusetts case, Marshal House, Inc. v. Rent Review and Grievance Bd. of Brookline, 260 N.E.2d 200 (Mass. 1970).  But that case did not address a minimum wage law either.  It addressed a local rent control law.  Moreover, in that case there was no “independent municipal power” that could serve as the basis for a rent control ordinance.  See id. at 204.  The Massachusetts Constitution, art. 89, § 6, provides a broad grant of “any power . . . which is not inconsistent with the constitution or laws” to Massachusetts municipalities.  See id. at 203.  That broad grant is limited by language in the same provision that is nearly identical to the civil relationships language in Article X, § 6(D) of the New Mexico Constitution:  “Nothing in this article shall be deemed to grant to any . . . town the power to . . . enact private or civil law governing civil relationships except as incident to the exercise of an independent municipal power.”  Massachusetts Constitution, art. 89, § 6.  The city in Marshal House, however, had not relied on any other “independent municipal power” granted to cities by the Massachusetts Legislature.  See Marshal House, 260 N.E.2d at 204 (“No contention appears to be made that there is any basis other than art. 89, s 6, for the town’s action in enacting the by-law.”)  In the instant case, by contrast, the City, in adopting the Ordinance, has invoked the New Mexico Legislature’s broad grants of “other independent municipal powers” to promote health, safety and welfare.

None of these non-New Mexico cases provide persuasive authority for Plaintiffs’ positions in this case.

B.                 The Ordinance Is Not A Law Governing Civil Relationships

As discussed above, the provision in the New Mexico Constitution denying municipalities the power to enact “private or civil laws governing civil relationships except as incident to the exercise of an independent municipal power” (Article X, §6(D)) adopts the language of the Model Constitutional Provisions for Municipal Home Rule and the Model State Constitution.  The exact meaning of the term “civil relationships” in that provision is uncertain.  See, e.g., Richard Briffault, What about the “Ism”? Normative and Formal Concerns in Contemporary Federalism, 47 Vand. L. Rev. 1303, 1343 (1994).  Contrary to Plaintiffs’ suggestion, no New Mexico court has ever interpreted this provision.  As noted, no court in any jurisdiction has ever determined whether and how this provision applies to a minimum wage law.

Dominguez v. Cruz, 95 N.M. 1, 617 P.2d 1322 (N.M. App. 1980) cited by Plaintiffs (See Pl. Resp. 11) has no bearing on the meaning of “civil relationships” as used in Article X, § 6(D).  The issue in that case was whether an oral agreement between cohabitating adults entered into under a promise of marriage can constitute an enforceable contract.  The court in Dominguez merely mentioned in passing that “marriage is only one type of civil relationship.”  Id. at 2.  There was no discussion of the term “civil relationships” as used in the New Mexico Constitution or as it applies to Home Rule powers of municipalities.[3]

Many of the cases interpreting provisions similar to Article X, § 6(D) attempt to draw a distinction between laws governing “private” or “civil” relationships from the exercise of traditional regulatory powers.  As noted in the City’s Moving Brief, a leading scholar suggests the restriction on laws governing civil relationships was intended to prevent municipalities from enacting comprehensive codes covering contract, tort, property and similar bodies of “private” law.  See Richard Briffault, What about the “Ism”? Normative and Formal Concerns in Contemporary Federalism, 47 Vand. L. Rev. 1303, 1343 (1994); see also Chuckney, 331 N.E.2d at 783 (noting in discussion of “civil relationships that “[f]or example, a city should not be able to enact its own separate law of contracts or domestic relations since these areas are unsuited to less than statewide legislation”); Mov. Br. 23.  Plaintiffs provide no support for their suggestion that any law regulating any aspect of a “contractual relationship” is a law governing civil relationships. [4]  Moreover, such a position clearly sweeps too broadly as it could limit long-accepted municipal powers to impose regulations to promote health and safety.[5] 

The preferable approach is to examine whether a particular regulation—in this case a local minimum wage law—can be said to regulate a “private” relationship, as distinct from a matter considered to be a matter of overwhelmingly public concern.  The minimum wage payable to workers can hardly be viewed as a matter to be determined privately between employer and employee as a simple matter of contract.  For almost seven decades it has been accepted that because of the intimate connection between wages and the general health, safety and welfare of a community, the decision regarding what minimum wage must be paid to workers is subject to extensive and continually changing federal, state and municipal regulation.  This aspect of the employment relationship has long been considered subject to public control; no private employer has the right to choose the minimum wage paid to workers.  Every employer in the United States is subject to a minimum wage set by federal, state or municipal authorities.  See, e.g., Fair Labor Standards Act, 29 U.S.C. § 201 et. seq.; New Mexico Minimum Wage Act, Section 50-4-1 NMSA 1978; Baltimore v. Sitnick, 255 A.2d 376, 378-79 (Md. 1969) (upholding municipal minimum wage).  Moreover, the federal minimum wage and other state and local minimums have continually been adjusted upward, and employers are therefore aware that the level of the minimum wage is subject to regulation by the political process rather than private contract.  Accordingly, whether relations between landlord and tenant or husband and wife or other contractual relations can be considered “private” or “civil” relationships has no bearing on whether the minimum wage payable to workers is a “private” or “civil” relationship.  It plainly is not and has not been treated as such since at least the 1930s.

In sum, the Ordinance establishing a minimum wage for Santa Fe is not a “private or civil law governing civil relationships” and even if it were, it clearly falls within the exception for laws enacted “incident to the exercise of an independent municipal power.”

II.                THE ORDINANCE IS NOT PREEMPTED BY STATE LAW BECAUSE IT DOES NOT CONFLICT WITH ANY STATE LAW

There is no dispute that under the New Mexico Constitution, municipalities have all legislative power “not expressly denied by general law.”  Art. X, § 6(D).  The phrase “expressly denied” means “that some express statement of the authority or power denied must be contained in such general law . . . otherwise no limitation exists.”  Apodaca v. Wilson, 86 N.M. 516, 521-22, 525 P.2d 876 (1974).  This includes “words or expressions which are tantamount or equivalent” to an express statement that a municipality “must comply and cannot operate to the contrary” of the general law.  Haynes v. Bonem, 114 N.M. 627, 634, 845 P.2d 150 (1992) (internal citations omitted).  Plaintiffs’ arguments that such express denials of municipal power to enact a local minimum wage are contained in several New Mexico statutes are completely without merit.

A.                 The Ordinance Is Not Preempted By The New Mexico Minimum Wage Act

Plaintiffs argue that the New Mexico Minimum Wage Act (“MWA”) preempts the Ordinance because the Ordinance provides greater protections to workers within the City of Santa Fe.  See Pl. Resp. 20.  But New Mexico courts have made it clear “that an ordinance may duplicate or complement statutory regulations.”  City of Hobbs v. Biswell, 81 N.M 778, 781, 473 P.2d 917 (Ct. App. 1970).  The fact that an Ordinance provides higher standards than a New Mexico statute creates no conflict.  See County of Los Alamos v. Montoya, 108 N.M. 361, 365, 772 P.2d 891 (Ct. App. 1989); Mov. Br. 49-50.  The higher minimum wage set by the Ordinance does not require an employer to violate the MWA.  Any employer complying with the Ordinance’s higher minimum wage is ipso facto in compliance with the MWA minimum. 

Plaintiffs argue that because the New Mexico Minimum Wage Act sets minimum wage standards for “all workers” in the state, the Act preempts the field, barring municipalities from enacting ordinances setting higher minimums.  See Pl. Resp. 20-22.  Plaintiffs cite no authority for this proposition because there is none.  Nor can they point to any words or phrases in the MWA that are “tantamount to an express denial” of municipal power.  There is no indication in the statute that higher minimums adopted to address unique local conditions, such as a particularly high cost of living, conflicts with the minimum wage set by the MWA.  As the New Mexico Supreme Court has held, “[t]he purpose [of the Home Rule Amendment] was to give local communities full power in matters of local concern, that is, in those matters which peculiarly affected the inhabitants of the locality, not in common with the inhabitants of the whole state.”  Haynes, 114 N.M. at 633.  Moreover, the New Mexico Attorney General specifically examined the issue of municipal minimum wage laws and found that the MWA does not preempt municipal ordinances establishing a higher minimum than the MWA.  The Attorney General reasoned that the MWA “only establishes a floor below which wages cannot be paid in municipalities” and that accordingly, there is no conflict created when a municipality establishes a higher minimum wage.  See Opinion of Attorney General of New Mexico attached hereto as an Appendix.

Plaintiffs argue that if the New Mexico legislature had intended to allow home rule municipalities to pass ordinances setting a minimum wage, the statute would read “all workers except those residing in home rule municipalities.”  Pl. Resp. 21.  This is patently illogical.  If the legislature had included such language there would currently be no minimum wage in Santa Fe, leaving workers without the protections of the MWA.  “All workers” throughout New Mexico will continue to be paid the state law minimu