1

Certiorari Denied, No. 31,833, July 30, 2009

IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

Opinion Number: 2009-NMCA-097

Filing Date: June 23, 2009

Docket No. 28,189

INTERNATIONAL ASSOCIATION

OF FIREFIGHTERS, Local 1687

AFL-CIO,

Plaintiff-Appellee,

v.

CITY OF CARLSBAD, a New Mexico

Municipal Corporation,

Defendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF EDDY COUNTY

Jane Shuler Gray, District Judge

The Martin Law Firm

W.T. Martin, Jr.

Kenneth D. Dugan

Lane T. Martin

Carlsbad, NM

for Appellee

Miller Stratvert P.A.

Virginia A. Anderman

Charlotte Lamont

Albuquerque, NM

for Appellant

OPINION

WECHSLER, Judge.
2

{1} The Public Employee Bargaining Act (PEBA), NMSA 1978, §§ 10-7E-1 to -26

(2003, as amended through 2005), provides for final, binding arbitration as an impasse

procedure in the event a public employer and an exclusive representative of its employees

reach an impasse that cannot be mediated in negotiations under the PEBA. Section 10-7E18(B). The PEBA further provides that an impasse resolution between such parties that

requires an expenditure of funds “shall be contingent upon the specific appropriation of

funds by the [L]egislature and the availability of funds.” Section 10-7E-17(E). We address

in this appeal the tension between these provisions. We hold, as a matter of statutory

interpretation, that Section 10-7E-17(E) (the contingency provision) prevails. The district

court reached the opposite conclusion. We therefore reverse its grant of summary judgment

to Plaintiff International Association of Firefighters, Local 1687, AFL-CIO (Union) and its

denial of summary judgment to Defendant City of Carlsbad (City) and, in turn, award

judgment to the City.

BACKGROUND

{2} The Union is the collective bargaining agent for the City’s firefighters. It is their

exclusive representative under Section 10-7E-15. The City and the Union have long

engaged in collective bargaining and have had numerous collective bargaining agreements

in place that set terms as to wages and working conditions. The last collective bargaining

agreement expired on April 14, 2006.

{3} In negotiating for a new collective bargaining agreement, the Union and the City

reached agreement on all issues except wages, on which issue they reached an impasse.

They entered into a memorandum of understanding (MOU), stating that “[t]he impasse

procedures as defined under [Section 10-7E-18(B)] will govern the process for resolution

of this impasse.” They selected an arbitrator, who, after conducting an arbitration

proceeding, entered an arbitration award, on May 25, 2007, based on the Union’s last, best

offer. The award addresses a three-year period, granting a 3.25% wage increase in the first

fiscal year, FY 2006-2007; a 15% one-time increase in addition to a 3% increase in FY

2007-2008; and a 3% increase in FY 2008-2009. The arbitrator specified that the award

“makes no determination as to the economic capability of the City of Carlsbad as that

decision must be left to the authority and determination of the City Council.” The City did

not appropriate funds in its FY 2007-2008 budget to put into effect the award’s one-time

15% increase.

{4} The Union filed a complaint seeking enforcement of the arbitration award and an

injunction, followed by a motion for partial summary judgment. The City responded with

a counter-motion for summary judgment. The district court held a hearing on the motions

and ruled from the bench in the Union’s favor. It later entered numerous orders in

conjunction with its ruling. The pertinent orders for the purposes of this appeal are (1) the

order granting summary judgment and confirming the arbitration award, (2) the amended

order issuing a writ of mandamus compelling the City to comply with the arbitration award,
3

and (3) the order granting the Union’s request for attorney fees and costs in the amount of

$46,927. The City appeals from these orders.

ENACTMENT AND RE-ENACTMENT OF IMPASSE PROCEDURES

{5} The Legislature originally enacted the PEBA in 1992 with a sunset provision to take

effect in 1999. NMSA 1978, §§ 10-7D-1 to -26 (1992, as amended through 1998) (repealed

1999). It re-enacted the PEBA in 2003 in mostly the same form as the original version. See

§§ 10-7E-1 to -26. See generally S. Barry Paisner & Michelle R. Haubert-Barela,

Correcting the Imbalance: The New Mexico Public Employee Bargaining Act and the

Statutory Rights Provided to Public Employees, 37 N.M. L. Rev. 357 (2007) (discussing the

history surrounding the enactment of New Mexico’s PEBA). The purpose in both versions

was the same, “to guarantee public employees the right to organize and bargain collectively

with their employers, to promote harmonious and cooperative relationships between public

employers and public employees and to protect the public interest by ensuring, at all times,

the orderly operation and functioning of the state and its political subdivisions.” Section 10-

7E-2; § 10-7D-2. In its re-enactment, the Legislature made a significant change to the

impasse resolution procedures. It instituted arbitration as a final procedure in resolving an

impasse in negotiations between a public employer and an exclusive representative of public

employees. See § 10-7E-18(B); § 10-7D-18(B). It also expanded the scope of language

limiting the ability of negotiating parties in circumstances that require the expenditure of

funds. See §§ 10-7E-17(E), 10-7E-18(B); § 10-7D-17(E).

{6} We begin our analysis with these provisions and their reflection of legislative intent.

We then address the Union’s several arguments that bear on the legislative intent. We

finally consider the Union’s position that genuine issues of material fact remain so as to

defeat summary judgment in favor of the City. 

LEGISLATIVE INTENT OF IMPASSE PROCEDURES 

{7} The impasse resolution procedures that the Legislature adopted in the PEBA in 2003

included two alternatives for resolving an impasse in negotiations. The parties could (1)

engage in mediation, which would lead to arbitration, or (2) enter into a written agreement

to use an alternative procedure. Section 10-7E-18 containing these procedures provides, as

pertinent to this appeal:

(B) The following impasse procedures shall be followed by all

public employers and exclusive representatives, except the state and the

state’s exclusive representatives:

(1) if an impasse occurs, either party may request from the

board or local board that a mediator be assigned to the negotiations unless the

parties can agree on a mediator. A mediator with the federal mediation and

conciliation service shall be assigned by the board or local board to assist
4

negotiations unless the parties agree to another mediator; and

(2) if the impasse continues after a thirty-day mediation

period, either party may request a list of seven arbitrators from the federal

mediation and conciliation service. One arbitrator shall be chosen by the

parties by alternately striking names from such list. Who strikes first shall be

determined by coin toss. The arbitrator shall render a final, binding, written

decision resolving unresolved issues pursuant to [Section 10-7E-17(E)] of the

[PEBA] and the Uniform Arbitration Act[, NMSA 1978, §§ 44-7A-1 to -32

(2001),] no later than thirty days after the arbitrator has been notified of his

or her selection by the parties. The arbitrator’s decision shall be limited to

a selection of one of the two parties’ complete, last, best offer. The costs of

an arbitrator and the arbitrator’s related costs conducted pursuant to this

subsection shall be shared equally by the parties. Each party shall be

responsible for bearing the cost of presenting its case. The decision shall be

subject to judicial review pursuant to the standard set forth in the Uniform

Arbitration Act.

(C) A public employer other than the state may enter into a written

agreement with the exclusive representative setting forth an alternative

impasse resolution procedure.

{8} Of the alternative procedures of Section 10-7E-18, the parties elected a hybrid; they

entered into an agreement, the MOU, that would fit the requirements of Subsection C and

agreed to proceed directly to arbitration under Subsection B. Acting under Subsection B,

the parties selected an arbitrator, who, as the statute demands, entered a written decision

within thirty days based on the Union’s last, best offer. Section 10-7E-18(B)(2). Subsection

B calls for the arbitrator’s decision to be a “final, binding” one. Section 10-7E-18(B)(2). 

{9} Section 10-7E-18(B) also provides for the arbitrator’s decision to be “pursuant to”

Section 10-7E-17(E). Section 10-7E-17(E) states, in pertinent part: 

An impasse resolution or an agreement provision by a public employer other

than the state or the public schools and an exclusive representative that

requires the expenditure of funds shall be contingent upon the specific

appropriation of funds by the appropriate governing body and the availability

of funds. . . . An arbitration decision shall not require the reappropriation of

funds.

The tension in the language of Section 10-7E-18(B)(2) and Section 10-7E-17(E) providing

for a final, binding arbitration decision that is contingent upon the appropriation and

availability of funds presents the issue in this case and requires interpretation of the PEBA.

The district court interpreted the PEBA to conclude that the arbitrator’s award was final and

binding on the parties. On appeal, we review de novo a district court’s interpretation of a
5

statute. City of Deming v. Deming Firefighters Local 4521, 2007-NMCA-069, ¶ 6, 141 N.M.

686, 160 P.3d 595. In doing so, we endeavor to fulfill the intent of the Legislature in

enacting the statute. Regents of Univ. of N.M. v. N.M. Fed’n of Teachers, 1998-NMSC-020,

¶ 28, 125 N.M. 401, 962 P.2d 1236. 

{10} The Union urges us to accept the district court’s interpretation by highlighting the

Legislature’s language in Section 10-7E-18(B)(2) that the arbitrator “shall render a final,

binding” decision. It supports its position with policy arguments stressing the legislative

purpose of guaranteeing public employees the right to organize and collectively bargain with

public employers. Section 10-7E-2. According to the Union, the Legislature intended

mandatory arbitration to be an essential tool of public employees in the collective bargaining

process because the PEBA forbids striking by public employees, a right available to private

sector employees. Therefore, the Union continues, unless mandatory arbitration is final and

binding, the collective bargaining right of public employees guaranteed by the PEBA will

not be meaningful.

{11} When engaging in statutory construction, we look first to the plain language of the

statute and construe it “in its entirety, considering all provisions in relation to each other.”

City of Deming, 2007-NMCA-069, ¶ 21. We seek to give meaning to all parts of the statute,

such that no portion is rendered surplusage or meaningless. Regents of Univ. of N.M., 1998-

NMSC-020, ¶ 28. With this foundation for our analysis, the Union argues that an

interpretation of the PEBA contrary to that made by the district court would render the

“final, binding” language of Section 10-7E-18(B)(2) meaningless. We reach the opposite

conclusion.

{12} Section 10-7E-18(B)(2) states that an arbitrator shall enter a final, binding decision

and also that such decision must be pursuant to Section 10-7E-17(E). Section 10-17E-17(E)

makes an impasse resolution that requires the expenditure of funds contingent upon the

appropriation and availability of funds. By framing the arbitrator’s authority in this manner

in Section 10-7E-18(B), the Legislature qualified the arbitrator’s authority with the language

of Section 10-7E-17(E). See Kahrs v. Sanchez, 1998-NMCA-037, ¶ 24, 125 N.M. 1, 956

P.2d 132 (filed 1997) (presuming that the Legislature is aware of existing law when enacting

statutes). Indeed, if we were to determine, as we believe the district court did, that the

arbitrator could act under Section 10-7E-18(B)(2) in a final and binding way without

reference to the requirements of Section 10-7E-17(E), we would be ignoring the legislative

language of Section 10-7E-18(B)(2) and considering its reference to Section 10-7E-17(E)

to be meaningless. See Regents of Univ. of N.M., 1998-NMSC-020, ¶ 28 (mandating that no

part of a statute is surplusage). Instead, we can give meaning to the two sections in relation

to each other by reading the qualification of Section 10-7E-17(E) to define the arbitrator’s

authority to render a final, binding decision: it is contingent upon the appropriation and

availability of funds when the decision requires the expenditure of funds. 

{13} As to the Union’s policy arguments, while we agree with the Union regarding the

importance of finality in the collective bargaining process, the legislative purpose of the
6

PEBA also includes ensuring “the orderly operation and functioning” of political

subdivisions. Section 10-7E-2. Section 10-7E-17(E) comports with this purpose because

it subjects an arbitration award to the appropriation and availability of funds of a political

subdivision. From the language of the PEBA, we cannot agree with the Union that the

Legislature, when considering a balance of the public interests, raised the need for binding

arbitration above the stability of public funds. Indeed, the 1992 version of the PEBA did not

provide for mandatory arbitration as an impasse procedure and, for public employers other

than the state and their employees’ exclusive representatives, provided only factfinding and

recommendations by a factfinder. Section 10-7D-18(B). It also prohibited strikes. Section

10-7D-21(A). When adopting arbitration in 2003, the Legislature did not mandate

arbitration but, instead, provided it as an option. And while the Legislature required that any

arbitration be final and binding, it subjected it to the contingency of the appropriation and

availability of funds that had been part of the 1992 version of the PEBA. Sections 10-7E17(E), 10-7E-18(B); § 10-7D-17(E). It continued to leave to governmental entities the

ability to manage and appropriate their public funds. See § 10-7E-17(E). The 2003 version

of the PEBA simply did not go as far as the Union argues.

THE UNION’S OTHER LEGISLATIVE INTENT ARGUMENTS

Limited Role of Section 10-7E-17(E)

{14} The Union makes several arguments differing from our interpretation. It argues in

part that the Legislature did not intend Section 10-7E-17(E) to apply in this case. According

to the Union, Section 10-7E-17(E) only provides that the contingency of appropriation and

availability of funds apply to “[a]n impasse resolution or an agreement provision by a public

employer . . . and an exclusive representative that requires the expenditure of funds.”

(Emphasis added.) It contends that if the procedure in this case is an impasse resolution, it

was “by” the arbitrator, not the City and the Union. It concludes that the only part of Section

10-7E-17(E) that applies to Section 10-7E-18(B) is the last sentence that forbids an

arbitration decision from requiring the reappropriation of funds.

{15} We cannot agree with the Union’s reading of the statutory provisions. First,

arbitration is an impasse resolution procedure that results in an impasse resolution. Section

10-7E-18(B) provides the “impasse procedures” to be followed by public employers other

than the state and their employees’ exclusive representatives. It provides arbitration as the

ultimate procedure. Section 10-7E-18(B)(2). The arbitration procedure requires a decision

by an arbitrator “resolving unresolved issues.” Id. Section 10-7E-18(B)(2) intends that the

decision and the procedure used to reach it constitute an impasse resolution. Second, the

2003 version of the PEBA modified both Section 10-7D-18(B) and Section 10-7D-17(E).

The Legislature made reference to Section 10-7E-17(E) in Section 10-7E-18(B) in 2003

when it enacted the new impasse resolution procedures. In addition, the 1992 version

provided in pertinent part: “Any agreement provision by a public employer other than the

state or the public schools and an exclusive representative that requires the expenditure of

funds shall be contingent upon the specific appropriation for wages by the appropriate
7

governing body and the availability of funds.” Section 10-7D-17(E). By changing the

language to pertain to “[a]n impasse resolution or an agreement provision by a public

employer other than the state or the public schools and an exclusive representative” and by

referencing Section 10-7E-17(E) in Section 10-7E-18(B), the Legislature linked Section 10-

7E-17(E) with Section 10-7E-18(B) so that the impasse resolution alternatives discussed in

Section 10-7E-18(B) applied to both sections. See Quantum Corp. v. State Taxation &

Revenue Dep’t, 1998-NMCA-050, ¶ 8, 125 N.M. 49, 956 P.2d 848 (stating that statutes

should be construed together with other statutes on the same subject matter). Third, as

drafted, Section 10-7E-18(B)(2) refers to the entirety of Section 10-7E-17(E), not only the

last sentence. If the Legislature intended to only refer to the last sentence, it could have done

so, or even incorporated it into Section 10-7E-18(B)(2). See Kahrs, 1998-NMCA-037, ¶ 24

(presuming that the Legislature is aware of existing law when enacting statutes).

{16} The Union also contends that our interpretation of the PEBA would render the last

sentence of Section 10-7E-17(E) meaningless. The Union states that the sentence was added

when the Legislature added the arbitration provision to Section 10-7E-18(B). It reasons that

“reappropriation” is a form of “appropriation,” and Section 10-7E-17(E) already provided

that an arbitrator could not “appropriate funds.” However, reappropriation is different from

appropriation because it involves a modification of existing appropriations. Moreover, the

Union contends that there is no reappropriation issue in this case. Additionally, we cannot

agree with the Union that Section 10-7E-18(B)(2) controls over Section 10-7E-17(E)

because it is the more specific statute. The legislative language specifically states its intent

that we construe Section 10-7E-17(E) as part of Section 10-7E-18(B)(2). This argument

would require that we ignore the Legislature’s specific reference to Section 10-7E-17(E) in

Section 10-7E-18(B)(2). 

Fairness and Due Process

{17} The Union further argues that our interpretation is unfair and violative of due

process. It contends that it is unfair because it is one-sided to allow the City the opportunity

to avoid an arbitration decision without giving the Union the same opportunity. It notes the

public policy favoring arbitration and cites Padilla v. State Farm Mutual Automobile

Insurance Co., 2003-NMSC-011, 133 N.M. 661, 68 P.3d 901, in which our Supreme Court

considered a provision in an insurance contract that provided for mandatory arbitration to

be binding only if it did not exceed the limits of the Mandatory Financial Responsibility Act

(MFRA), NMSA 1978, §§ 66-5-201 to -239 (1978, as amended through 2003), and

otherwise allowed either party to file a de novo appeal. Padilla, 2003-NMSC-011, ¶ 2. The

Court held the contractual provision to be void as substantively unconscionable because it

was incompatible with the public policies of encouraging arbitration and protecting persons

from uninsured drivers as expressed in the MFRA. Id. ¶¶ 2, 13-14. However, in this case,

we are not addressing the application of statutory policies to a contractual provision between

private parties, as in Padilla. Rather, our issues involve the interpretation of the

Legislature’s policies that it set forth in the PEBA. As we have discussed, the Legislature

engaged in a balancing of policies in enacting the PEBA. The contingency language of
8

Section 10-7E-17(E) that protects the public fiscally when funds are not available to meet

an arbitrator’s decision fulfills one of the stated purposes in the statute. See § 10-7E-2.

{18} With regard to due process, the Union also relies on Board of Education of Carlsbad

Municipal Schools v. Harrell, 118 N.M. 470, 882 P.2d 511 (1994), to contend that due

process restraints apply to arbitration under the PEBA. In Harrell, our Supreme Court

applied due process requirements to the compulsory arbitration process of NMSA 1978,

Section 22-10-17.1 (1993). Harrell, 118 N.M. at 477, 882 P.2d at 518. It stressed the

difference between voluntary and compulsory arbitration.

While voluntary arbitration may be conducted using any procedure

acceptable to the participants, compulsory arbitration must comport with due

process. [V]oluntary arbitration and compulsory arbitration are

fundamentally different if only because one may, under our system, consent

to almost any restriction upon or deprivation of right, but similar restrictions

or deprivations, if compelled by government, must accord with procedural

and substantive due process.

Id. (alteration in original) (internal quotation marks and citation omitted). It concluded that

the arbitration was compulsory, even though the employee contractually consented to submit

his grievance to arbitration, because the statute imposed a mandatory arbitration requirement

and that the statute violated due process insofar as it restricted judicial review of the

arbitrator’s decision. Id. at 476, 486, 882 P.2d at 517, 527. The PEBA is very different.

Section 10-7E-18(C) enables a public employer other than the state and an exclusive

representative to agree in writing to any impasse resolution procedure, notwithstanding the

procedures set forth in Section 10-7E-18(B)(2) that call for arbitration. Arbitration becomes

mandatory only if the parties elect to proceed under Section 10-7E-18(B), as the Union and

the City did by their MOU. Harrell does not apply to this case. Moreover, the contingency

provisions of Section 10-7E-17(E) that recognize that a public entity may not have the funds

available to comply with an arbitrator’s decision are reasonably designed to fulfill the

statutory purpose of protecting the public interest “by ensuring, at all times, the orderly

operation and functioning” of the City. Section 10-7E-2; see Rex, Inc. v. Manufactured

Hous. Comm., 2003-NMCA-134, ¶ 15, 134 N.M. 533, 80 P.3d 470 (explaining that an

argument for due process requires a balancing of the private interest and the risk of

erroneous deprivation against the government’s interest).

Interpretation of the MOU

{19} The Union makes the additional argument that the parties agreed to binding

arbitration because they did not refer to Section 10-7E-17(E) in the MOU. The MOU states:

“The impasse procedures as defined under [Section 10-7E-18(B)] will govern the process

for resolution of this impasse.” According to the Union, because the MOU refers only to the

impasse procedures of Section 10-7E-18(B) and does not reference Section 10-7E-17(E),

Section 10-7E-17(E) should not be considered to resolve this impasse. We do not agree.
9

The parties expressly agreed to use the “impasse procedures as defined under” Section 10-

7E-18(B). Those procedures specifically reference Section 10-7E-17(E). Even though the

parties did not mention Section 10-7E-17(E), the impasse procedures of Section 10-7E18(B), as designated by the parties, incorporate Section 10-7E-17(E).

Appropriation of Funds

{20} The Union alternatively argues that even if Section 10-7E-17(E) applies, the

arbitrator’s salary award did not require the appropriation of funds so as to trigger Section

10-7E-17(E). The Union suggests, citing Municipality of Anchorage v. Anchorage Police

Department Employees Ass’n, 839 P.2d 1080 (Alaska 1992), that the City could have

accommodated the arbitration award by shifting funds or by cutting other expenditures.

However, Municipality of Anchorage is not on point. It involved an ordinance that mandated

binding arbitration, and the pertinent issue was whether the potential for judicial

enforcement of an arbitrator’s award under the ordinance unconstitutionally delegated the

power to appropriate funds. Id. at 1089. The court observed in that context that the

executive and legislative branches of government must provide the required funding for

collective bargaining arbitration awards because they are part of the contractual negotiations.

Id. at 1090-91. The case before us does not raise that issue. Moreover, as distinguished

from the ordinance in Municipality of Anchorage, the PEBA provides that arbitration

decisions requiring the expenditure of funds are contingent upon the appropriation and

availability of funds. Section 10-7E-17(E).

{21} Nor do we agree with the Union that the district court’s judgment, confirmation of

the arbitrator’s award, and writ of mandamus require the City’s compliance without regard

to any appropriation. The argument simply ignores the question of the appropriation and

availability of funds as set forth in Section 10-7E-17(E).

ABSENCE OF GENUINE ISSUE OF MATERIAL FACT

{22} The district court granted the Union’s motion for summary judgment and denied the

City’s counter-motion for summary judgment. When the district court acts on countermotions for summary judgment based on a common legal issue, this Court may reverse both

the grant of one motion and the denial of the other and award judgment on the previously

denied motion. Cuevas v. State Farm Mut. Auto. Ins. Co., 2001-NMCA-038, ¶ 6, 130 N.M.

539, 28 P.3d 527. 

{23} The Union asserts that it would not be appropriate for us to award judgment to the

City because genuine issues of material fact remain that must be resolved at trial. See Rule

1-056(C) NMRA (stating that summary judgment is appropriate if the summary judgment

record shows “that there is no genuine issue as to any material fact and that the moving party

is entitled to judgment as a matter of law”). The Union first contends that issues of fact

remain concerning its claims that (1) the City breached its obligation under the PEBA “to

negotiate in good faith by arbitrarily and without adequate grounds failing to honor the
10

arbitration award” and (2) the City defrauded the Union by “pretending that the arbitration

award would bind it and luring [the Union] into executing the arbitration agreement.”

However, the Union did not raise these claims in its complaint. It mentions such claims in

one of its briefs in conjunction with the counter-motions for summary judgment, referring

to Paragraphs 27-29 of its complaint. However, those paragraphs merely recite allegations

that the City budgeted for portions, but not all, of the arbitrator’s award. The complaint does

not contain any claim that the City breached its obligation under the PEBA to negotiate in

good faith or that it defrauded the Union.

{24} The Union also contends that there are issues of fact that must be resolved due to the

ambiguity of the MOU. But we do not agree that the MOU is ambiguous. As we have

discussed, it clearly requires the parties to follow the impasse procedures of Section 10-7E18(B). That section unambiguously incorporates Section 10-7E-17(E). There is no

remaining factual issue. 

CONCLUSION

{25} Under the PEBA, an arbitration award requiring a public employer other than the

state to expend funds is contingent upon the appropriation and availability of funds. We

reverse the district court’s grant of summary judgment to the Union and denial of summary

judgment to the City. We award judgment to the City. Because we reverse on the merits,

we also reverse the district court’s award of attorney fees and costs to the Union.

{26} IT IS SO ORDERED.

____________________________________

JAMES J. WECHSLER, Judge

WE CONCUR:

____________________________________

CYNTHIA A. FRY, Chief Judge

____________________________________

ROBERT E. ROBLES, Judge

Topic Index for Intl. Assn. of Firefighters v. City of Carlsbad, No. 28,189

CP CIVIL PROCEDURE

CP-SJ Summary Judgment

EL EMPLOYMENT LAW

EL-CB Collective Bargaining

EL-LU Labor Unions
11

GV GOVERNMENT

GV-PE Public Employees

RE REMEDIES

RE-AN Arbitration

ST STATUTES

ST-IP Interpretation