Clause, the Supreme Court has explained that it “think[s] it fair to say from a review of the cases cited dealing with the term ‘donation,’ as found in this proviso of the Constitution, that the word has been applied, in its ordinary sense and meaning, as a ‘gift,’ an allocation or appropriation of something of value, without consideration to a ‘person, association or public or private corporation.’ ” Village of Deming v. Hosdreg Co., 62 N.M. 18, 28, 303 P.2d 920, 926-27 (1956). The Supreme Court of New Mexico has stricken transactions under the Anti-Donation Clause in circumstances involving an outright gift of money or property to a private entity with no exchange of adequate consideration. See Chronis v. State ex rel. Rodriguez, 100 N.M. 342, 348, 670 P.2d 953, 959 (1983)(<HOLDING>); State ex rel. Mechem v. Hannah, 63 N.M. 110,
holding that even though labeled a tax on conducting retail liquor business challenged statute was nevertheless a penalty designed to punish the violation of state liquor laws holding that legislative diminishment of tax obligation constituted an unconstitutional subsidy to the liquor industry in violation of the antidonation clause holding inter alia that a creditor may take a security interest in a licensees liquor license holding that a tax credit to liquor licensees against taxes owed to the state was an unconstitutional subsidy of the liquor industry holding place as used in statute defining liquor nuisance was not limited to a particular building but included entire area where illicit liquor business was conducted