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Brief of Amici Curiae
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Brief of Amici Curiae
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Last modified
1/26/2010 4:41:42 PM
Creation date
7/29/2009 3:03:22 PM
Metadata
Fields
Template:
Water Supply Protection
File Number
8230.2F
Description
Colorado Supreme Court Appeal
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
7/26/2004
Author
David L. Robbins, Lee E. Miller, Patricia L. Wells, Robert G. Weiss, John M, Dingess
Title
Brief of Amici Curiae
Water Supply Pro - Doc Type
Court Documents
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validity of the leg:.slation should be assiduously avoided if an alternative construction consistent <br />with legislative intent is availabie.i4 Perry Park Water & Sanitation .Dist. v. Cordillera Corp., <br />818 P.2d 728, 732 (Coio. 1991); accord Colo. Ground Water Comm ',n v. Eagle PeakFarms, <br />Ltd., 919 P.2d 212, 221 (Colo. 1996); City of Greenwood Village v, i°etitioners for Proposed <br />Ciry of Centennial, 3 P.3d 427 at 440 (Courts "do not lightly declare a statute unconstitz.itional"). <br />Both the history leading up to the passage of Senate Bi11216 and the legislative history of the bill <br />establish that the General Assembly intended to place reasonable lim.its on the size and scope of <br />water rights for F:ICD purposes to prevent them from being used to tie up the entire flow of the <br />river or a substarLtial portion thereof for extreme recreational uses th,3t would frusirate the <br />optimum use of water for other beneficial uses. <br />Tlie genesis of the current controversy can be traced to this C:ourt's 1992 decision in City <br />of Thornton v. City of Fort Collins, 830 P.2d 915 (Co1o. 1992). There, this Court for the first <br />time held that controlling water in its natural course or location by a. structure or device can be a <br />"diversion" witrin the meaning of section 37-92-103(4). Id. at 929-30. Reading i:his decision as <br />recognition of iri-channel flow rights for recreational putposes so long as the wate.r was <br />controlled in its natural course, the communities of Golden, Vail, arid Breckenridge filed <br />applications seeking decrees for in-channel flow rights for kayak courses. These rights were <br />granted by the tivater courts and eventually affirmed as a matter of law based on 3-3 votes in this <br />Court. See State Eng. v. City of Golden, 69 P.3d 1027 (Colo. 2003;1; State Eng. v.. Eagle River <br />Water and Sanltation Dist., 69 P.3d 1028 (Colo. 2003). <br />j This pr(:sumption in favor of constitutionality means that a party challenging a statute on constitutional <br />grounds must prove unconstiturionality "beyond a reasonable doubt." Ciry of Greenwood Village v. Petitioners for <br />Proposed City of ?entennial, 3 P.3d 427, 440 (Colo. 2000). <br />11
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