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This case asks whether the State of New Mexico鈥檚 actions enabling pollution from oil and gas extraction, and its failure to control that pollution, violate the New Mexico Constitution鈥檚 Pollution Control Clause, Inherent Rights Clause, Due Process Clause, and Equal Protection Clause. Our brief urges the New Mexico Supreme Court to answer those questions by retiring its 鈥渋nterstitial approach鈥� to state constitutional interpretation鈥攚hich looks first to federal doctrine when interpreting state constitutional provisions that arguably have U.S. Constitutional analogues鈥攁nd instead interpreting the New Mexico Constitution holistically and independently. This independent approach, we explain, will ensure that New Mexicans can enjoy鈥攁nd enforce鈥攖he rights guaranteed to them in their unique founding document.