New Mexico Supreme Court rules Governor exceeded spending authority over federal COVID funds

Scope: Federal (New Mexico)

Branch: Judicial

Severity: Green

Date occurred: November 14, 2023

Phase: 2021-2023

In State ex rel. Candelaria v. Grisham, the New Mexico Supreme Court ruled that Gov. Michelle Lujan Grisham exceeded her constitutional authority by unilaterally spending over a billion dollars in federal ARPA pandemic relief funds without legislative appropriation. The court initially ruled against the Governor on November 17, 2021, siding unanimously with state senators, and issued a full written opinion in 2023 establishing a new state framework for resolving separation-of-powers disputes over federal funds, similar to approaches used in Colorado, Oklahoma, and Massachusetts.

Constitutional basis: New Mexico judiciary enforcing the state constitution's appropriations clause (Art. IV, Sec. 30) against executive overreach

Sources

  • KOB.com
  • Santa Fe New Mexican
  • State Court Report
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