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Notice of Apparent Positional Bias and Motion for Disqualification of Justice Hobbs, With Authorities
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Notice of Apparent Positional Bias and Motion for Disqualification of Justice Hobbs, With Authorities
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Last modified
1/26/2010 4:41:42 PM
Creation date
7/29/2009 2:50:26 PM
Metadata
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Template:
Water Supply Protection
File Number
8230.2F
Description
Colorado Supreme Court Appeal
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
8/23/2004
Author
Cynthia F. Covell
Title
Notice of Apparent Positional Bias and Motion for Disqualification of Justice Hobbs, With Authorities
Water Supply Pro - Doc Type
Court Documents
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disclosed gounds for disqualification were (l) that the anzici cui-iae in Golden included his former <br />clients, Northern and Colorado Water Congress,9 and (2) that part of the matter in controversy in <br />Golden included the meaning and continuing viability of Fort Collins, where Justice Hobbs had <br />made nearly identical arguments to those being rnade in Golden. Id. <br />His recusal without explanation in the Golden cases creates the appearance that the r.ecusal <br />was due, at Ieast in part, to a bias or "bent of mind" regarding the meaning of FoYt Collins and the <br />restrictions that should be imposed on recreational in-charmel water rights. The same appearance <br />of a positional bias is pxesent in thi.s appeal because the CWCB is advocating the same restrictive <br />view of recreational in-channel water rights and the same narrow interpretation of Fort Collins that <br />were advocated in the Golden cases. Therefore, recusal or disqualification is warranted here as well. <br />C. Justice Hobbs' Recent Extrajudicial Statements Contribute to the Appearance <br />of a Positional Bias. In A.ugust of 2003, after the passage of SB 216, after this Court had affirmed the Golden <br /> <br />cases by operation of law, and less tlian a month before trial of Upper Gunnison's recreational in- <br />channel diversion case, 7ustice Hobbs was interviewed on the public radio program Colorado <br />9 Though neither Northern nor Colorado Water Congress chose to request amici curiae <br />status in this appeal, they both participated in the SB 216 legislative hearin.gs and, thus, are <br />clearly interested in the issues framed by the CWCB's appeal. Covell aff. 14. Indeed, Northern <br />presented the SB 216 Legislative Statement (Covell aff. ¶ 5), and the CWCB relies on the ' <br />legislative statement to support its xestrictive interpretation of the SB 216 amendments and <br />Upper Gunnison's claims thereiinder (Opening Brief at 14). Further, Northern's legislativ.e <br />statement refers to Fort Collins as authority for the recreational in-channel water rights <br />recognized by SB 216 (Covell aff. 15, Attachment E), and thus raises the same issues as the ones <br />identified in this motion as the basis of Upper Gunnison's. concem about the appearance of a <br />positional bias. <br />11
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