1

IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

Opinion Number: 2009-NMCA-047

Filing Date: March 25, 200

Docket No. 27,027

JESSIE ROMERO,

Plaintiff-Appellant,

v.

ROBERT PARKER and

SIVAD ENTERPRISES, LLC,

Defendants-Appellees,

and

SIVAD ENTERPRISES, LLC,

Counterclaimant-Appellee,

v.

JESSIE ROMERO,

Counterdefendant-Appellant.

APPEAL FROM THE DISTRICT COURT OF SANTA FE COUNTY

James A. Hall, District Judge

J. Ronald Boyd

Santa Fe, NM

for Appellant

Mary E. Walta, P.C.

Mary E. Walta

Santa Fe, NM
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for Appellees

OPINION

WECHSLER, Judge.

{1} Plaintiff Jessie Romero (Romero) appeals from the district court’s summary

judgment in favor of Defendants Robert Parker (Parker) and Sivad Enterprises, LLC (Sivad).

We address whether the Construction Industries Licensing Act (the CILA), NMSA 1978, §§

60-13-1 to -59 (1967, as amended through 2007), which precludes an unlicensed contractor

from seeking compensation for construction work that can only be performed by a licensed

contractor, also bars an unlicensed subcontractor from recovering compensation for

construction work from the general contractor. We hold that it does. We also address

whether the CILA bars a general contractor who did not act responsibly in hiring an

unlicensed subcontractor from recovering compensation already paid to the unlicensed

subcontractor, and, again, we hold that it does. Additionally, we hold that equitable

principles do not apply in this situation. We further hold that Parker was not an agent for

an undisclosed principal, Sivad, and is thus not personally liable to Romero. We affirm in

part and reverse in part.

BACKGROUND

{2} Romero, who is in the business of construction, performed work for Sivad, operating

a backhoe, laying stone, and performing other masonry work without a contractor’s license.

Sivad is a general contractor. Parker was Sivad’s agent for contracts and construction

projects, and Steve Davis (Davis) was Sivad’s member/manager. Romero dealt primarily

with Parker and Davis and claims to have not known about Sivad until after a conflict arose.

Although Romero claims that he worked for Parker, and much of Romero’s dealings were

with Parker, he, in fact, worked for Sivad, and Parker was Sivad’s agent. Romero did not

bid on any work, and there were no written contracts. Sivad had Romero working on

construction projects at five residences (the construction projects) at once, each with several

assignments. Romero prepared invoices for payment, which show a variety of billing

methods including per hour, per load, per square foot, and per item. Romero was paid for

a portion of his work and filed a complaint for breach of the construction contracts for the

remainder. Romero alleges that he fully performed all work under the contracts, demanded

payment, and was refused. Defendants filed a motion for summary judgment, claiming that

Romero could not recover compensation under the complaint because he was operating as

an unlicensed contractor contrary to the CILA requirements. Romero argued that genuine

issues of material fact still existed and that his compensation claims were not barred because

Parker knew that Romero was not licensed and nevertheless allowed Romero to continue

work with reasonable expectation that he would be fairly compensated at the conclusion of

each job assignment. Parker denies knowing that Romero was not licensed at the time the

work was assigned.
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{3} The district court granted Defendants’ motion for summary judgment on four of the

five construction projects, finding that some portion of Romero’s work at those construction

projects required a contractor’s license, that he did not have one, and that, therefore, he was

barred from recovering compensation pursuant to the CILA and Gamboa v. Urena, 2004-

NMCA-053, 135 N.M. 515, 90 P.3d 534. In response to Romero’s motion to amend the

complaint to add an equitable estoppel claim, the district court denied the motion on the

basis that Gamboa made the amendment “futile.” The order was certified for interlocutory

appeal, and this Court denied the application.

{4} Sivad then asserted a counterclaim for a refund of the money that Sivad had already

paid Romero for his work on the construction projects. Romero filed a second motion to

amend the complaint to add a claim of damages against Parker for misrepresentation,

claiming that Parker falsely represented himself, not Sivad, as the general contractor.

Thereafter, Sivad filed a motion for summary judgment on its counterclaim, arguing that the

CILA, Gamboa, and Mascarenas v. Jaramillo, 111 N.M. 410, 806 P.2d 59 (1991), mandated

that Sivad receive a full refund of compensation already paid to Romero. The district court

denied Romero’s second motion to amend the complaint, again on the basis that “[t]he

proposed amendment of the Complaint is futile under New Mexico law.” Sivad’s motion

for summary judgment on its counterclaim was stricken without prejudice as untimely filed

under the scheduling order.

{5} Romero’s answer to Sivad’s counterclaim asserted as affirmative defenses essentially

the same equitable claims he had sought to bring by way of his first and second motions to

amend the complaint. Romero alleged that Parker knew Romero was unlicensed, that Parker

had misrepresented to Romero that Romero did not need a contractor’s license to work on

the construction projects, and that Parker had assured Romero that he would be paid

regardless. Romero also asserted that Sivad was not entitled to a refund of amounts already

paid to Romero under its counterclaim because Sivad is not the “innocent consumer”

protected by the CILA and applicable case law. Romero added that “[t]he equitable

doctrines of unclean hands, unjust enrichment, estoppel and implied covenant . . . should

apply herein.” Although the district court had previously stricken Sivad’s motion for

summary judgment as untimely, it apparently granted a hearing on the motion at a later date.

As a result of that hearing, the district court granted in part and denied in part Sivad’s motion

for summary judgment on the counterclaim, ruling that, under New Mexico law, Sivad was

entitled to be reimbursed for compensation already paid to Romero, an unlicensed

contractor.

{6} In its final judgment, the district court adopted Defendants’ proposed findings and

conclusions and noted the summary judgments already granted against the complaint and in

favor of the counterclaim. The district court ruled that Parker, as Sivad’s agent, was not

individually liable to Romero and required Romero to reimburse Sivad for work on four of

the five construction projects, minus the amount owed to Romero for the fifth construction

project, at which no unlicensed work was completed by Romero. Romero appeals.
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STANDARD OF REVIEW

{7} “Summary judgment is appropriate [when] there are no genuine issues of material

fact and the movant is entitled to judgment as a matter of law.” Montgomery v. Lomos Altos,

Inc., 2007-NMSC-002, ¶ 16, 141 N.M. 21, 150 P.3d 971 (internal quotation marks and

citation omitted). “We review the [district court’s] application of the law to the undisputed

facts de novo.” Gamboa, 2004-NMCA-053, ¶ 7.

RECOVERY BY AN UNLICENSED CONTRACTOR

{8} The New Mexico Legislature “casts a harsh eye on contracting without a license.”

Id. ¶ 12; see also Mascarenas, 111 N.M. at 414, 806 P.2d at 63 (stating that unlicensed

contractors may not retain payments as a matter of public policy, even if the consumer had

knowledge that the contractor was unlicensed). Section 60-13-30(A) states that “[n]o

contractor shall . . . bring or maintain any action . . . for the collection of compensation for

the performance of any act for which a license is required . . . without alleging and proving

that such contractor was a duly licensed contractor at the time the alleged cause of action

arose.” Contracting includes “constructing, altering, repairing, installing or demolishing any

. . . building, stadium or other structure; . . . leveling or clearing land; [or] excavating earth.”

Section 60-13-3(A). Thus, the express language of Section 60-13-30(A) and the public

policy behind its mandate “to protect the public from incompetent and irresponsible

builders,” Peck v. Ives, 84 N.M. 62, 66, 499 P.2d 684, 688 (1972), operate to bar unlicensed

contractors’ suits for compensation, “even when they seek compensation for construction

work fully and satisfactorily performed.” Triple B Corp. v. Brown & Root, Inc., 106 N.M.

99, 101, 739 P.2d 968, 970 (1987). Mascarenas further explained that “[t]he public policy

behind the licensing requirement of the [CILA] is so strong that the element of consumer

knowledge is of no consequence in our decision.” Mascarenas, 111 N.M. at 414, 806 P.2d

at 63. The definition of “contractor” includes subcontractors. Section 60-13-3(B).

{9} Romero did not have a contractor’s license at any time during his performance of any

of the construction work on all five construction projects, and some of his work required a

license. Romero argues that he should be entitled to payment on the work that he performed

that did not require a license because he was paid wages on some assignments and because

he claims to have contracted with Parker separately for each job assignment, some of which

did not require a license. Romero further argues that the district court erred in its initial

granting of summary judgment for Defendants on four of the five properties when a material

fact—how many sites required a license—was disputed.

{10} First, we address Romero’s contention that he worked only for wages. The CILA

does exempt from its provisions “an individual who works only for wages.” Section 60-13-

3(D)(13). Therefore, if Romero worked only for wages, he would not be considered an

independent contractor, subject to the CILA. The CILA’s definition of “wages” is

“compensation paid to an individual by an employer from which taxes are required to be

withheld by federal and state law.” Section 60-13-2(I). For Romero to have received wages,
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he must be deemed Sivad’s employee and not an independent contractor. The CILA states

that individuals who provide labor or services to a contractor for compensation are

employees of the contractor unless they meet all of the standards “indicative of an

independent contractor.” Section 60-13-3.1(A). Those standards are as follows: (1) the

individual is “free from direction and control over the means and manner of providing the

labor or services”; (2) the individual is responsible for obtaining his own business

registrations or licenses; (3) the individual supplies his own tools and equipment; (4) the

individual “has the authority to hire and fire employees”; (5) payment to the individual is

made “upon completion of the performance of specific portions of a project or . . . on the

basis of a periodic retainer”; and (6) the individual “represents to the public that the labor

or services are to be provided by an independently established business.” Id.

{11} The facts of this case do not support a conclusion that Romero was Sivad’s

employee. Although Romero admitted at trial that he was not an employee, he argued that

his situation was unique. However, Romero operated as a masonry contractor with his own

equipment and had his own employees who assisted him in the masonry and excavation

work. His invoices to Sivad for incomplete work were under the name JR Stone Masonry.

These facts satisfy a majority of the standards listed above—that Romero was responsible

for his own registration and licensing, that he had his own tools and equipment, that he had

his own employees, and that he represented to the public that he was a business. See id.

{12} Romero also claims that he should be treated as an employee, not an independent

contractor, because he was assigned work based on individual job assignments and because

he billed for certain work on an hourly basis. Although it may be true that Romero was

assigned specific jobs within each construction project site and that some of his invoices

billed hourly, ultimately he was paid after each assignment was completed. As stated above,

the fifth standard that would result in characterization as an independent contractor is that

payment to the individual is made “upon completion of the performance of specific portions

of a project or . . . on the basis of a periodic retainer.” Id. Regardless of how Romero

showed his work on his invoices, it is undisputed that he was paid “upon completion of the

performance of specific portions of a project,” satisfying the fifth standard of an independent

contractor. Id. Moreover, the CILA specifies in its definition of a contractor that an

individual may be exempted from the act if he receives wages and “no other form of

compensation.” Section 60-13-3(D)(10), (12); see also § 60-13-3(D)(13) (specifying that

an individual may be exempt if he works only for wages); § 60-13-3(D)(14)(a) (specifying

that an individual may be exempt if “the work is not part of a larger . . . operation undertaken

by the same individual”). Romero was paid for work in various forms, not only wages, and

his work was part of a larger operation undertaken by him and his employees.

{13} Additionally, Romero provided no evidence that Sivad or its agent Parker directed

or controlled the details of the masonry and excavation work that Romero provided at the

construction sites, the first standard in the list establishing status as an independent

contractor. See § 60-13-3.1(A). Finally, Romero admitted to presenting no evidence that

Sivad withheld applicable employee-related state and federal taxes from Romero’s invoice
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amounts or that Sivad contemplated including Romero and his employees under Sivad’s

workers’ compensation insurance coverage. See § 60-13-2(I) (including in its definition of

“wages” that taxes are withheld by federal and state law). The district court correctly found

that Romero did not receive only wages for compensation. As such, in consideration with

the other factors discussed, he should be treated as an independent contractor under the

CILA.

{14} Second, we address Romero’s claim that he was assigned work based on individual

job assignments and that, therefore, he should be allowed to recover compensation for

assignments that did not require a license. Romero’s argument appears to rely on the CILA

provision that exempts from the definition of contractor “any person who merely furnishes

materials or supplies at the site without fabricating them into, or consuming them in the

performance of, the work of a contractor.” Section 60-13-3(D)(1). But Romero did not

simply deliver material or supplies to the construction sites; he excavated the sites and

fabricated the stone and other supplies into walls, patios, and other masonry structures for

which a contractor’s license is required. See §§ 60-13-3(A), 60-13-12.

{15} We also reject Romero’s claim that there is a factual dispute as to how many of the

construction projects involved work that required a license. The actual work that Romero

performed is not in dispute; and the district court analyzed those undisputed facts to

determine that, as a matter of law, four of the five construction projects involved work that

required a license. Specifically, the district court found that Romero was deemed “an

unlicensed contractor with respect to certain of the subcontracted construction work he

performed on each of the [c]onstruction [p]rojects.” In so finding, the district court relied

on the affidavit of Andy Dalmy, the licensing manager of the Construction and Industries

Division, which showed the results of his personal inspection of Romero’s work.

{16} Moreover, even if Romero’s work had been assigned individually within each

construction project site, this Court’s opinion in Gamboa does not allow Romero to separate

his construction acts in such a manner to evade the licensing requirements under the CILA.

Gamboa, 2004-NMCA-053, ¶ 16 (explaining in a case in which a contractor effectively

asked this Court to “excuse the construction work he performed without a license and

exempt him from the requirements of the CILA” that doing so “would encourage contractors

to engage in creative contract drafting whereby they attribute all charges to the cost of

materials and supplies and charge nothing for labor”). Thus, the district court correctly

defined the construction projects as the five residences provided in the record and not by

individual job assignments within those locations.

EQUITABLE PRINCIPLES SUPERCEDED BY THE CILA

{17} We next address Romero’s argument that the CILA does not expressly deny all

equitable actions for recovery of compensation. We are not persuaded. In Triple B Corp.,

our Supreme Court held that, in addition to claims for breach of contract, Section 60-13-

30(A) also bars an unlicensed contractor from bringing suit for the recovery of compensation
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under a quantum meruit or quasi-contract theory. Triple B Corp., 106 N.M. at 103, 739 P.2d

at 972. The public policy behind the CILA’s mandate to protect people from incompetent

and irresponsible contractors, see § 60-13-1.1; Peck, 84 N.M. at 66, 499 P.2d at 688,

operates to bar unlicensed contractors’ suits for compensation even when the recipient of the

work is thereby unjustly enriched. Triple B Corp., 106 N.M. at 102, 739 P.2d at 971

(refusing to recognize an “equitable defense of unjust enrichment because the Legislature

. . . necessarily authorized the unjust enrichment of the recipients of work performed by

unlicensed contractors” and stating that the statute’s policy “must override the judicial

principle that disfavors unjust enrichment”). Further, the express language in Section 60-13-

30(A) prohibiting an unlicensed contractor from bringing “any action in any court of the

state for the collection of compensation” is a broad statement of the prohibition against

unlicensed contractors’ use of the courts to recover compensation under any theory, whether

in law or in equity.

{18} In arguing that his equitable claims should not be barred, Romero also relies on

language in Peck, in which our Supreme Court stated that it was “reluctant to construe the

statute more broadly than necessary” and that the “statute should not be transformed into an

unwarranted shield for the avoidance of a just obligation.” Peck, 84 N.M. at 66, 499 P.2d

at 688 (internal quotation marks omitted). Peck adopted the doctrine of substantial

compliance to avoid the harshness of Section 60-13-30 for contractors who had substantially

complied with the CILA licensing provisions at the inception of the construction work. Peck,

84 N.M. at 66, 499 P.2d at 688. In the context of Peck, the words “just obligation”

contemplate that a contractor who had complied with the CILA licensing requirements when

beginning the construction work thereby retained a “just obligation” for the collection of

compensation. See id. The Court did not apply this concept to an unlicensed contractor,

such as Romero, who has not complied at all with the CILA licensing requirements. As

such, Romero does not retain a “just obligation” for the collection of compensation, which

the express language of the CILA bars. 

{19} Romero further relies on Triple B Corp. as creating a “glimmer of hope” for his

equitable defenses. In that case, the unlicensed contractor had failed to establish the

elements of equitable estoppel, and our Supreme Court, while expressly denying the

unlicensed contractor’s unjust enrichment defense, did not expressly deny an equitable

estoppel exception to Section 60-13-30. Triple B Corp., 106 N.M. at 102, 739 P.2d at 971.

Our subsequent cases clearly indicate, however, that an unlicensed contractor’s action for

compensation is barred on all equitable principles due to the fact that “the public importance

of discouraging such prohibited transactions outweighs equitable considerations of possible

injustice as between the parties.” Gamboa, 2004-NMCA-053, ¶ 17 (internal quotation marks

and citation omitted); see also Mascarenas, 111 N.M. at 414, 806 P.2d at 63 (“The public

policy behind the licensing requirement of the [CILA] is so strong that the element of

consumer knowledge is of no consequence in our decision.”). We agree with the district

court’s finding that equitable principles were not an appropriate remedy for Romero.

CONTRACTOR’S RECOVERY OF COMPENSATION
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PAID TO AN UNLICENSED SUBCONTRACTOR

{20} Romero argues that Sivad cannot receive a refund of compensation paid to Romero

for Romero’s alleged violation because the CILA protects only consumers, of which

contractors are excluded. Sivad disagrees and argues that Romero cannot retain

compensation already received because Mascarenas bars an unlicensed contractor from

retaining compensation for work performed in violation of the CILA. 111 N.M. at 414, 806

P.2d at 63. We address each argument in turn and conclude that, although a contractor is not

excluded from the CILA’s protection of “the people,” Sivad is nevertheless barred from

recovery in this case because of its failure to be a responsible contractor under the CILA.

{21} Although Sivad’s counterclaim for recovery of payments made to Romero involved

the same arguments applied to Defendants’ defense of Romero’s claims, the issues are not

the same. In our discussion above, we address an unlicensed subcontractor attempting to

receive compensation for work he performed that required a license. Sivad’s counterclaim

deals with a licensed contractor attempting to retrieve compensation paid for work

performed by an unlicensed subcontractor that the licensed contractor hired. This is a matter

of first impression in New Mexico. Reule Sun Corp. v. Valles, 2008-NMCA-115, ¶ 11, 144

N.M. 736, 191 P.3d 1197 (raising, without addressing, the issue of “whether a duly licensed

contractor may recover for work performed by an unlicensed subcontractor”), cert. granted,

2008-NMCERT-008, 145 N.M. 255, 195 P.3d 1267.

{22} Romero argues that Section 60-13-30(A) only bars actions for compensation between

the unlicensed contractor or subcontractor and the ultimate consumer of the

construction—that is, the public, the landowner, or the homeowner. We do not agree that

the statute or our case law is as limited as Romero argues. Section 60-13-1.1 states that the

purpose of the CILA is to “promote the general welfare of the people of New Mexico by

providing for the protection of life and property by adopting and enforcing codes and

standards for construction, alteration, installation, connection, demolition and repair work.”

Our case law has indicated that the statute seeks to protect “the public.” See Mascarenas,

111 N.M. at 413, 806 P.2d at 62 (referring to “consumers” and “the public” when discussing

the purpose of the CILA); Peck, 84 N.M. at 66, 499 P.2d at 688 (including “the public” when

discussing the CILA’s purpose). Yet, no case states that a contractor is not a consumer or

a member of “the people.” See generally Mascarenas, 111 N.M. at 413-14, 806 P.2d at 62-

63; Gamboa, 2004-NMCA-053 ¶¶ 13, 15-16; see also § 60-13-1.1. The point in Mascarenas

was not to limit the scope of the CILA, but to restate the Legislature’s intent to ensure that

no unlicensed contractor may recover from anybody for work performed that requires a

license. See Mascarenas, 111 N.M. at 413-14, 806 P.2d at 62-63. We see no reason to limit

the CILA’s scope to only consumers.

{23} However, although the CILA does not only protect consumers, it does not allow

recovery by Sivad in this case. In addition to the CILA’s stated purpose to protect people

from unscrupulous contractors, it also states that, to effect its purpose, the Legislature

intends that “contractors be required to furnish and maintain evidence of responsibility.”
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Section 60-13-1.1(C); see Mascarenas, 111 N.M. at 413, 806 P.2d at 62 (interpreting the

purpose of the CILA as remedying the wrong of “exploitation of the public by incompetent

and unscrupulous contractors who are unable or unwilling to obtain a license”). We construe

the sections of the CILA together to give effect to the Legislature’s intent. See High Ridge

Hinkle Joint Venture v. City of Albuquerque, 1998-NMSC-050, ¶ 5, 126 N.M. 413, 970 P.2d

599 (explaining that, when “several sections of a statute are involved, they must be read

together so that all parts are given effect”). “In determining legislative intent, we look not

only to the language used in the statute, but also to the object sought to be accomplished and

the wrong to be remedied.” Mascarenas, 111 N.M. at 413, 806 P.2d at 62.

{24} Sivad cites Mascarenas for the contention that Romero should not be permitted to

retain compensation received for licensed work for which he had no license. See id. at 414,

806 P.2d at 63. However, the facts in Mascarenas are different from the present case. In

Mascarenas, a landowner hired an unlicensed contractor to do licensed work and then sought

reimbursement of compensation already paid. Id. at 411-12, 806 P.2d at 60-61. Mascarenas

held, “[a]s a matter of public policy, an unlicensed contractor may not retain payments made

pursuant to a contract which requires him to perform in violation of the [CILA]” and granted

the landowner a full refund. Id. at 414, 806 P.2d at 63. However, in the present case, a

licensed general contractor is seeking recovery of payments made to an unlicensed

subcontractor that the general contractor hired. There is no indication that Romero withheld

information from Sivad or that Sivad, prior to hiring, would not have obtained information

concerning Romero’s licensure upon reasonable inquiry. From the Legislature’s requirement

that contractors “furnish and maintain evidence of responsibility,” we infer that contractors

must behave responsibly. See § 60-13-1.1(C). The Legislature’s purpose of protecting the

people of New Mexico from unscrupulous contractors would be thwarted if, after mandating

that contractors behave responsibly and requiring that contractors possess applicable

licenses, general contractors were then allowed recovery of compensation paid to unlicensed

subcontractors that they irresponsibly hired and assigned to do work requiring a license.

Therefore, we reverse the district court’s order that Sivad be permitted to recover payments

already made to Romero.

PERSONAL LIABILITY OF AGENTS

{25} Romero finally argues that he believed that he was working for Parker rather than

Sivad and that he did not know that Sivad was even involved. Romero therefore contends

that Parker is personally liable to him as an agent for an undisclosed principal. Parker

argues, however, that he has no personal liability to Romero because there was substantial

evidence to support the district court’s decision against Romero on this issue and because

Romero’s claim that Parker is liable to Romero as an “undisclosed agent” of Sivad is

flawed as a matter of law. We agree with Parker.

{26} In reviewing a substantial evidence claim, “[t]he question is not whether substantial

evidence exists to support the opposite result, but rather whether such evidence supports the

result reached.” Las Cruces Prof’l Fire Fighters v. City of Las Cruces, 1997-NMCA-044,
10

¶ 12, 123 N.M. 329, 940 P.2d 177. “Additionally we will not reweigh the evidence nor

substitute our judgment for that of the fact finder.” Id. The district court found that Parker

was the agent of Sivad, that Romero knew about Sivad, and that Romero’s contract was with

Sivad. In our review of the record, we conclude that substantial evidence supports the

district court’s findings: Sivad’s signs and permits were posted at the construction sites,

Romero received checks with Sivad’s name on them, and other employees informed Romero

that they worked for Sivad. The district court did not err in finding that Sivad was not an

undisclosed principal, and, thus, Parker is not individually liable to Romero.

CONCLUSION

{27} We conclude that the CILA bars both an unlicensed subcontractor from recovering

compensation from a general contractor and a general contractor who did not act responsibly

in hiring an unlicensed subcontractor from recovering compensation already paid to the

unlicensed subcontractor. We also conclude that equitable principles are not applicable to

actions addressed under the CILA. We therefore affirm in part and reverse in part.

{28} IT IS SO ORDERED.

JAMES J. WECHSLER, Judge

WE CONCUR:

JONATHAN B. SUTIN, Judge

RODERICK T. KENNEDY, Judge

Topic Index for Romero v. Parker, No. 27,027

CP CIVIL PROCEDURE

CP-SJ Summary Judgment

CM COMMERCIAL LAW

CM-AA Agency, Agent

CM-CT Contractors and Subcontractors

CM-LC Licensed Contractor

CN CONTRACTS

CN-PP Public Policy
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EL EMPLOYMENT LAW

EL-IC Independent Contractor

GV GOVERNMENT

GV-LC Licensing 

MS MISCELLANEOUS STATUTES

MS-CL Construction Industries Licensing Act

RE REMEDIES

RE-EQ Equity

ST STATUTES

ST-IP Interpretation