The New Mexico Supreme Court has denied an inmate's constitutional challenge to the state corrections department's property acquisition procedures in a case that tests the boundaries of prisoner rights under state law.
In *Franklin v. Martinez*, decided Jan. 26, the court issued a dispositional order quashing inmate Bryce Franklin's petition for writ of habeas corpus. Franklin had challenged the New Mexico Corrections Department's inmate property policy, arguing it violated his constitutional rights.
The case began when Franklin filed an amended petition for writ of habeas corpus in the Third Judicial District Court, which denied his request. Franklin then sought review by the state's highest court through a petition for writ of certiorari under Rule 12-501 NMRA.
The Supreme Court granted certiorari on April 23, 2025, allowing the case to proceed. After both parties filed briefs, the court heard oral arguments on Dec. 9, 2025, before issuing its decision.
At the heart of Franklin's challenge was whether inmates have a constitutionally protected property interest in acquiring items through the corrections department's established procedures. Franklin argued that the policy governing inmate property acquisition violated Article II, Sections 4 and 18 of the New Mexico Constitution.
Article II, Section 4 of the New Mexico Constitution provides due process protections, stating that no person shall be deprived of life, liberty or property without due process of law. Section 18 prohibits the taking of private property for public use without just compensation.
The court rejected Franklin's constitutional argument. In its dispositional order, the court concluded that Franklin "failed to establish there is a constitutionally protected property interest in acquiring property through the New Mexico Corrections Department's inmate property policy under Article II, Sections 4 and 18 of the New Mexico Constitution."
This finding suggests the court viewed the corrections department's property procedures as administrative policies rather than creating enforceable property rights for inmates. The distinction is significant because constitutional due process protections typically apply only when a person has a recognized property or liberty interest at stake.
The court also noted a procedural issue that limited the scope of its review. Franklin had not argued before the court whether he possessed a "constitutionally protected liberty interest" in acquiring property through the corrections policy. Because this argument was not presented, the court declined to address the liberty interest question.
Citing precedent from *In re Adoption of Doe* (1984), the court explained it would not consider arguments not raised by the parties. This procedural limitation meant the court's analysis focused solely on the property interest claim that Franklin did present.
The decision represents an unpublished opinion of the New Mexico Supreme Court. Under Rule 12-405 NMRA, unpublished decisions have restrictions on their citation in legal proceedings, limiting their precedential value in future cases.
Franklin was represented by Kurt J. Mayer of Albuquerque. The state's position was defended by Attorney General Raúl Torrez and Assistant Solicitor General Sarah M. Karni, also of Albuquerque.
The case originated as an original proceeding on certiorari from a decision by District Judge Richard M. Jacquez in the Third Judicial District Court, which had denied Franklin's initial habeas corpus petition.
Habeas corpus petitions are legal mechanisms that allow inmates to challenge the legality of their confinement or conditions of imprisonment. These petitions often raise constitutional questions about due process, cruel and unusual punishment, or other fundamental rights.
The court's ruling suggests that while inmates retain basic constitutional protections, administrative policies governing property acquisition within correctional facilities may not create enforceable constitutional rights. This distinction reflects the broader legal principle that not every government benefit or procedure creates a protected property interest.
The decision comes as courts nationwide continue to define the scope of prisoner rights under various constitutional provisions. While inmates do not forfeit all constitutional protections upon incarceration, courts often apply different standards when evaluating claims related to prison administration and security.
For corrections officials, the ruling may provide guidance that properly drafted administrative policies for inmate property management are less likely to create constitutional obligations. However, the decision's unpublished status limits its broader precedential impact.
The case highlights the ongoing tension between prisoner rights and institutional administration. While the specific details of the corrections department's property policy were not detailed in the court's order, the ruling suggests the procedures were viewed as administrative rather than rights-creating.
Franklin's case demonstrates the procedural complexities inmates face when challenging prison conditions or policies. The court's emphasis on the specific constitutional arguments presented underscores the importance of comprehensive legal strategy in prisoner rights litigation.
The decision stands as the final word on Franklin's constitutional challenge, with no further appellate options available from the state's highest court.