Living Cross Ambulance Serv. v. N.M. Pub. Regulation Comm'n

Summary

The Court vacated the Public Regulation Commission’s grants of temporary authority and a permanent certificate to AMR because the Commission allowed Living Cross’s former attorney to represent AMR during a substantive hearing while a timely disqualification motion was pending. The Court held that the Commission should have stayed the proceedings until resolving the conflict, and that admitting the entire temporary-authority hearing record and derivative testimony at the permanent-certification hearing was plain error. The Court did not reach the sufficiency of the evidence or public-need issues. No separate opinions were filed.