January 27, 2026- Felix Valdez v. Board of Trustees of the Juan Bautista Valdez Land Grant, No. A-1-CA-42290

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IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO	1
Opinion Number: __________	2
Filing Date: January 27, 2026	3
No. A-1-CA-42290	4
FELIX VALDEZ and GRACE VALDEZ,	5
Plaintiffs/Counterdefendants-Appellants,	6
v.	7
BOARD OF TRUSTEES OF THE JUAN	8
BAUTISTA VALDEZ LAND GRANT,	9
Defendant/Intervenor/Counterclaimant-Appellee,	10
11
and	12
JUAN BAUTISTA VALDEZ LAND	13
GRANT, INC.,	14
Defendant-Appellee,	15
and	16
JUAN DURAN JR., URSULA DURAN,	17
ELIZABETH HOLLAND, and LEVI C.	18
VALDEZ,	19
Defendants.	20
APPEAL FROM THE DISTRICT COURT OF RIO ARRIBA COUNTY	21
Kathleen McGarry Ellenwood, District Court Judge	22
Court of Appeals of New Mexico
Filed 1/27/2026 7:09 AM

Atler Law Firm, P.C.	1
Timothy J. Atler	2
Jazmine J. Johnston	3
A. Howland Swift	4
Albuquerque, NM	5
Pottow Law, LLC	6
Michael T. Pottow	7
Santa Fe, NM	8
for Appellants	9
New Mexico Legal Aid	10
David Benavidez	11
Santa Fe, NM	12
Joe Lennihan	13
Santa Fe, NM	14
for Appellees	15

OPINION	1
HANISEE, Judge.	2
{1} 	This case stems from a quiet title dispute over land that falls within the Juan	3
Bautista Valdez Land Grant in Rio Arriba County, New Mexico. A federal patent	4
from 	1913 	confirms 	the 	“private 	land 	claim” 	to 	“the 	[h]eirs, 	[l]egal	5
[r]epresentatives, and [a]ssigns of Juan Bautista Valdez.” Plaintiffs Felix and	6
Grace Valdez sought to quiet title in their favor, claiming they are direct descendants	7
of Juan Bautista Valdez and thus “heirs” in the language of the federal patent.	8
Defendants Juan Bautista Valdez Land Grant, Inc. and Board of Trustees of the Juan	9
Bautista Valdez Land Grant moved for partial summary judgment, claiming that	10
Plaintiffs were seeking to retry matters resolved by the federal patent. The district	11
court agreed, concluded that it lacked jurisdiction, and granted Defendants’ motion	12
for partial summary judgment. Despite doing so, however, the district court reached	13
the merits, made findings of fact, and quieted title in Defendants without Defendants	14
requesting it to do so. Plaintiffs appeal, and we reverse.	15
BACKGROUND	16
{2} 	Planning to sell land they believed they owned pursuant to a warranty deed,	17
Plaintiffs discovered a clerical error in need of correction. Plaintiffs therefore	18

2
initiated an action to quiet title. Defendant Juan Bautista Valdez Land Grant, Inc.0F
1
1
answered the complaint, and later moved for partial summary judgment primarily	2
on the grounds that Plaintiffs were impermissibly seeking to retry a federal patent	3
issued in 1913. The patent confirmed a decree that was issued in response to a	4
lawsuit brought by Juan Bautista Valdez’s heirs in the court of private land claims	5
in 1893, which then had congressionally sanctioned authority to examine and settle	6
land grant claims. See Chavez v. Chavez de Sanchez, 1893-NMSC-007, ¶ 9, 7 N.M.	7
58, 32 P. 137. The patent stated: “[T]he private land claim known as the Juan	8
Bautista 	Valdez 	Grant, 	has 	been 	duly 	confirmed 	to 	the 	[h]eirs, 	[l]egal	9
[r]epresentatives, and [a]ssigns of Juan Bautista Valdez.”	10
{3} 	In their response, Plaintiffs argued that their intent was for the district court to	11
quiet title based on the patent and on private conveyances that occurred thereafter.	12
Agreeing with Defendants, the district court found that “title to the disputed land	13
was adjudicated” in the decree and patent, that the “patent conveys a common and	14
undivided interest in the heirs, legal representatives and assigns of Juan Bautista	15
Valdez,” that neither the decree nor the patent “award[s] title to any individuals or	16
describe[s] any private tracts of land,” and that the decree and patent “are conclusive	17
1 Plaintiffs brought the complaint against additional defendants, namely, John
(Juan) Duran, Jr., Ursula Duran, Elizabeth Holland, and Levi C. Valdez. But these
defendants later defaulted and are not included among the defendants referred to in
this opinion.

3
on the question of title to the disputed land.” The district court found that “Plaintiffs	1
ha[d] no right of action to try title to the disputed land in this [c]ourt,” and that title	2
to the disputed land should thus be quieted in Defendants.	3
{4} 	Plaintiffs appeal, contending that the district court erred in its findings.	4
Plaintiffs first argue that they sought interpretation rather than a retrial of the patent	5
and that the district court therefore had jurisdiction to consider their claim to quiet	6
title and assess their chain of title arguments. Second, Plaintiffs point to genuine	7
issues of material facts that they argue should have precluded summary judgment.	8
Among the genuine issues of material fact Plaintiffs mention is chain of title:	9
Plaintiffs argue that the patent granted title to individuals rather than to a community,	10
that—unlike Defendants—they can trace their chain of title back to the patent, and	11
that they are descendants of Juan Bautista Valdez, all entitling them to the disputed	12
land. Plaintiffs contend that the district court erred in failing to resolve their chain of	13
title contentions and not requiring Defendants to prove their own. We address both	14
arguments in turn.	15
DISCUSSION	16
A. 	Standard of Review	17
{5} 	“We review the district court’s grant of summary judgment de novo . . .	18
view[ing] the facts in a light most favorable to the party opposing summary	19
judgment and draw[ing] all reasonable inferences in support of a trial on the merits.”	20

4
Freeman v. Fairchild, 2018-NMSC-023, ¶ 14, 416 P.3d 264 (internal quotation	1
marks and citations omitted). We first address whether the district court erred by	2
finding it lacked jurisdiction. We then address whether genuine issues of material	3
fact existed and should have precluded summary judgment.	4
B. 	The District Court Has Jurisdiction to Interpret Federal Patents	5
{6} 	The Treaty of Guadalupe Hidalgo, which both ceded western lands held by	6
Mexico to the United States and guaranteed respect for existing property rights, “was	7
not self-executing, and Congress established different adjudication systems, by	8
which Mexican landowners were required to demonstrate the legitimacy of their	9
claims under Spanish and Mexican law to have their rights confirmed by the United	10
States.” Montoya v. Tecolote Land Grant ex rel. Tecolote Bd. of Trs., 2008-NMCA-	11
014, ¶ 4, 143 N.M. 413, 176 P.3d 1145. Among the executing systems established	12
by Congress was the Act of July 22, 1854 (“An Act to establish the offices of	13
Surveyor-General of New Mexico, Kansas, and Nebraska”), ch. 103, § 8, 10 Stat.	14
308 (1854), whereby the appointed surveyor general would “conduct administrative	15
proceedings to determine the status of land grant claims,” including the “origin,	16
nature, character, and size of . . . land grant[s].” Tecolote Land Grant ex rel. Tecolote	17
Bd. of Trs., 2008-NMCA-014, ¶¶ 6, 21. After such proceedings were conducted, the	18
surveyor general would recommend land grants to Congress for confirmation, and if	19
Congress agreed with the recommendations, it would issue what was known as a	20

5
patent. Id. ¶ 10. Patents confirmed title in the individuals or communities determined	1
by the surveyor general and were “confirmatory,” “final,” and “conclusive.” Id. ¶ 24	2
(internal quotation marks and citation omitted). This meant that courts were not	3
permitted to “go behind [the patent] and determine the character or nature of the	4
grant from the antecedent documents.” Id. (internal quotation marks and citation	5
omitted). In other words, with this confirmation system in place, courts were barred	6
from retrying title, or going behind patents to reanalyze rightful ownership in	7
response to disgruntled plaintiffs claiming title from Mexican or other sources that	8
existed prior to the patent. Once Congress had spoken, in the form of a confirmatory	9
patent, courts lost jurisdiction to weigh antecedent land grants and Congress’s	10
“action was conclusive and binding on the court.” Id. ¶ 23 (internal quotation marks	11
and citation omitted).	12
{7} 	Although 	their 	scope 	is 	limited, 	courts 	are 	still 	permitted 	to 	make 	a	13
“determination simply of the meaning of the act of Congress confirming the grant.”	14
H. N. D. Land Co. v. Suazo, 1940-NMSC-061, ¶ 21, 44 N.M. 547, 105 P.2d 744;	15
Tecolote Land Grant ex rel. Tecolote Bd. of Trs., 2008-NMCA-014, ¶ 23 (same). So,	16
while courts do not have jurisdiction to decide “the meaning, effect or validity” of	17
land grants or other antecedent documents to patents, they can look at the meaning	18
of the patent itself, as is shown by cases interpreting postpatent chains of title. See	19
H. N. D. Land Co., 1940-NMSC-061, ¶ 21; Tecolote Land Grant ex rel. Tecolote	20

6
Bd. of Trs., 2008-NMCA-014, ¶ 24; Martinez v. Mundy, 1956-NMSC-037, ¶¶ 7-8,	1
61 N.M. 87, 295 P.2d 209 (recognizing the validity of a patent in its analysis of chain	2
of title documents issued after the patent), overruled on other grounds by Evans Fin.	3
Corp. v. Strasser, 1983-NMSC-053, ¶ 11, 99 N.M. 788, 664 P.2d 986; Caranta v.	4
Pioneer Home Improvements, Inc., 1970-NMSC-030, ¶¶ 3, 6, 81 N.M. 393, 467 P.2d	5
719 (same).	6
{8} 	We read Plaintiffs’ complaint as a request for the district court to quiet title	7
by interpreting the language of the patent, rather than a collateral attack on or a	8
request to go behind a patent. We therefore disagree with the district court’s finding	9
that Plaintiffs did not “seek title based on any interpretation of the patent.” We	10
explain.	11
{9} 	To begin, the district court was correct that the law governing federal patents	12
prohibits land claimants from “looking behind” a patent to show a competing title.	13
See Bustamante v. Sena, 1978-NMSC-067, ¶ 8, 92 N.M. 72, 582 P.2d 1285	14
(“Further, a patent . . . constitutes an implied finding of every fact which is made a	15
prerequisite to its issue; and . . . a court cannot go behind it and look to the antecedent	16
proceedings on which it is founded.”). The district court is likewise correct that once	17
a valid patent is issued, no claimant may bring an action to retry title. See St. Louis	18
Smelting & Refining Co. v. Kemp, 104 U.S. 636, 640 (1881). But the district court	19
misperceived that such is what Plaintiffs were trying to do. Rather than asking the	20

7
district court to look behind the patent, Plaintiffs asked the court to quiet title in light	1
of the plain language of the patent and documents issued after the patent, documents	2
that Plaintiffs argue establish the ensuing chain of title. While the former effort is	3
barred by New Mexico and federal precedent, the latter is permissible. The district	4
court confused the two and was mistaken in its finding that it lacked jurisdiction.	5
{10} 	Plaintiffs emphasized their intent to quiet title rather than retry the patent in	6
their response to Defendants’ motion for partial summary judgment, in their own	7
motion for summary judgment, and on appeal. Defendants likewise acknowledged	8
in the pleadings their own understanding that interpretation, rather than looking	9
behind the patent, was 	Plaintiffs’ intent. That 	Plaintiffs 	included 	documents	10
predating the patent in this case does not mean that Plaintiffs are asking the court to	11
retry the patent. Rather, as Plaintiffs explained, Plaintiffs presented evidence of the	12
history of the land grant to support one of their arguments: that the patent was issued	13
to individuals and not a community. By including some pre-1913 documents,	14
Plaintiffs sought to aid the court in interpreting the language of the patent in their	15
request to quiet title, not to challenge the patent. For these reasons, we reverse the	16
district court’s finding that Plaintiffs sought to retry title and therefore that the	17
district court lacked jurisdiction. To be clear, we hold that Plaintiffs requested the	18
district court to quiet title by interpreting the 1913 patent and subsequent, not	19

8
antecedent, events relevant to the property at issue and that the district court has	1
jurisdiction to do so.	2
C. 	Summary Judgment Was Premature	3
{11} 	Having held that the district court has jurisdiction to consider and resolve	4
Plaintiffs’ request to interpret the 1913 patent and to quiet title in their favor, we	5
remand to the district court. We hold that the district court’s finding that it lacked	6
jurisdiction prevented it from comprehensively determining the issue of whether	7
genuine issues of material fact existed, and we therefore cannot affirm its order	8
reaching the merits and view its findings as in need of a second look. Because the	9
district court addressed several of the merits despite believing it lacked jurisdiction,	10
however, we offer additional guidance for the district court to consider on remand.	11
{12} 	“In determining whether summary judgment should be granted, the court	12
should view the matters presented in a light most favorable to support the right of	13
trial on the merits.” Blauwkamp v. Univ. of N.M. Hosp., 1992-NMCA-048, ¶ 34, 114	14
N.M. 228, 836 P.2d 1249. A district court “is not to weigh the evidence . . . and	15
decide an issue of fact; the court must decide only whether a material issue of fact	16
exists. If one does exist, then the cause must proceed to a trial on the merits.”	17
Cebolleta Land Grant, ex rel. Bd. of Trs. of Cebolleta Land Grant v. Romero, 1982-	18
NMSC-043, ¶ 13, 98 N.M. 1, 644 P.2d 515. Furthermore, “[w]hen the facts before	19

9
the court are reasonably susceptible to different inferences, summary judgment is	1
improper.” Blauwkamp, 1992-NMCA-048, ¶ 34.	2
{13} 	Here, parties dispute two major issues: first, the meaning of the 1913 patent	3
and whether such embodied individual, private ownership; and second, whether	4
either party can trace their chain of title back to the federal patent. Our review of the	5
pleadings on which the district court relied suggests that genuine issues of material	6
fact regarding both disputes may preclude summary judgment had the district court	7
assumed jurisdiction and examined the issues more comprehensively.	8
{14} 	First, the meaning of the 1913 patent is heavily disputed by both parties,	9
calling into question the district court’s findings as to its interpretation—findings,	10
we note, that are problematic largely because they were reached despite a supposed	11
lack of jurisdiction. For one, the district court, while acknowledging its lack of	12
jurisdiction, nonetheless found that the patent conveys a “tenancy in common or a	13
joint tenancy,” as though the two were interchangeable. The language of the patent,	14
however, lacks any terminology designating the land grant as a joint tenancy. See	15
NMSA 1978, § 47-1-36 (1971) (explaining that it must be “expressly declared in the	16
will or conveyance to be a joint tenancy”); see also NMSA 1978, § 47-1-15 (1851-	17
1852) (“All interest in any real estate, either granted or bequeathed to two or more	18
persons other than executors or trustees, shall be held in common, unless it be clearly	19
expressed in said grant or bequest that it shall be held by both parties.”). Therefore,	20

10
we can only make sense of the first finding, that the patent conveys a tenancy in	1
common. We nonetheless remand the issue to the district court for a more in-depth	2
analysis to determine whether the patent conveyed a tenancy in common.	3
{15} 	The district court next seemingly operated under the belief that a tenancy in	4
common is incompatible with individual ownership. This is incorrect. Rather, if	5
property is “common land” of a land grant, then individuals who can show that they	6
are valid heirs “may hold the property as tenants in common” with other entities,	7
such as “the Board of Trustees.” Cebolleta Land Grant, ex rel. Bd. of Trs. of	8
Cebolleta Land Grant, 1982-NMSC-043, ¶ 10. In general, “[t]enants in common	9
hold distinct titles,” meaning that each owner is “solely and severally seized of a	10
share.” Bankers Tr. Co. v. Woodall, 2006-NMCA-129, ¶ 14, 140 N.M. 567, 144 P.3d	11
126 (internal quotation marks and citation omitted). “All the valid heirs to the land	12
grant are considered to hold title as tenants in common.” Apodaca v. Tome Land &	13
Improvement Co. (NSL), 1978-NMSC-018, ¶ 21, 91 N.M. 591, 577 P.2d 1237. We	14
take this law to mean that if the 1913 patent did indeed grant a tenancy in common,	15
which we leave for the district court to decide, such does not prohibit Plaintiffs from	16
private ownership of the disputed land, as long as they can trace their title back to	17
the federal patent. Further, “we see nothing in the language of the patent . . . to	18
indicate any intention that there should be any restraint upon alienation.” L Bar	19
Cattle Co. v. Bd. of Trs. of Town of Cebolleta Land Grant, 1941-NMSC-057, ¶ 12,	20

11
46 N.M. 26, 120 P.2d 432. Thus, the various conveyances made since the patent are	1
not invalidated by the patent’s potential designation of the land as a common	2
tenancy.	3
{16} 	As to the second central issue in district court, whether each party could trace	4
their title back to the federal patent, we observe that the language of the patent	5
specifies Juan Bautista Valdez and his heirs, legal representatives, and assigns as	6
predecessors in interest. Plaintiffs claim they can trace their chain of title back to the	7
patent and show they are direct descendants of Juan Bautista Valdez, thus qualifying	8
them as “his heirs” under the language of the patent. While Defendants argue that	9
Plaintiffs are not explicitly named in the patent and thus have no title and that	10
Defendants’ title is superior because it stems from the federal patent, Plaintiffs noted	11
how Defendants provided little to no support that their chain of title could be traced	12
to the language of the patent. Defendants cited law that “[i]t is fundamental that a	13
patent is the highest evidence of title,” see Bustamante, 1978-NMSC-067, ¶ 8	14
(internal quotation marks and citation omitted), and that the party that can trace its	15
title back to the federal patent holds superior title. See Bd. of Cnty. Comm’rs, Luna	16
Cnty. v. Ogden, 1994-NMCA-010, ¶ 20, 117 N.M. 181, 870 P.2d 143. But Plaintiffs	17
essentially argued that there was a missing link between Defendants and the plain	18
language of the patent; we agree that careful consideration of the evidence on remand	19
might bear this out. Indeed, Defendants’ claim that the federal patent conveyed title	20

12
to them as predecessor in interest must be established by evidence in order to succeed	1
on summary judgment.	2
{17} 	In our view, a careful consideration of evidence on remand may reveal	3
disputes of material fact that are genuine and warrant a trial on the merits, keeping	4
in mind that a “party seeking to quiet title . . . must recover upon the strength of	5
[their] own title and not on the claimed weakness of [their] adversary.” Martinez v.	6
Martinez, 1997-NMCA-096, ¶ 12, 123 N.M. 816, 945 P.2d 1034. This means that	7
even if Plaintiffs fail to trace their chain of title to the patent, or, put another way,	8
prove their strength of title, title will not automatically default to Defendants but	9
must first be proven in its own right. See id. (explaining that the defendants have	10
“the burden of proof to establish the validity of their claim of ownership in the	11
disputed property”); Frost v. Markham, 1974-NMSC-046, ¶ 12, 86 N.M. 261, 522	12
P.2d 808 (“[T]itle in appellees does not follow absent proof of better title in	13
themselves.”). While the district court remains free on remand to consider motions	14
for summary judgment, including Plaintiffs’, it must do so applying the patent at	15
issue and in light of events related to the property’s chain of title in ensuing years.	16
D. 	The District Court Erred by Granting Relief Beyond That Requested	17
{18} 	We briefly remind the district court that its order responded to pleadings	18
wherein Plaintiffs, not Defendants, were seeking to quiet title. Thus the district court	19
erred by going beyond the relief requested and quieting title in Defendants. See Rule	20

13
1-056 NMRA (where a party seeking recovery must move for relief and show that	1
no genuine issue of material fact exists and that they are entitled to a judgment as a	2
matter of law).	3
CONCLUSION	4
{19} 	We hold that the district court erred in its finding that Plaintiffs sought a	5
retrial of the patent rather than an interpretation thereof, and its ensuing finding that	6
it lacked jurisdiction. We also hold that the district court erred in granting summary	7
judgment under circumstances and evidence that did not as yet establish the absence	8
of genuine issues of material fact. Finally, we hold that the district court erred in	9
granting relief that was not requested and quieting title in Defendants. We reverse	10
and remand for a trial on the merits.	11
{20} 	IT IS SO ORDERED.	12
_________________________	13
J. MILES HANISEE, Judge	14
WE CONCUR:	15
___________________________	16
JANE B. YOHALEM, Judge	17
___________________________	18
GERALD E. BACA, Judge	19