This case asks whether the State of New Mexico’s actions enabling pollution from oil and gas extraction, and its failure to control that pollution, violate the New Mexico Constitution’s 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 “interstitial approach” to state constitutional interpretation—which looks first to federal doctrine when interpreting state constitutional provisions that arguably have U.S. Constitutional analogues—and instead interpreting the New Mexico Constitution holistically and independently. This independent approach, we explain, will ensure that New Mexicans can enjoy—and enforce—the rights guaranteed to them in their unique founding document.