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Case No. 90SA514 Opening Brief for the Appellant
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Case No. 90SA514 Opening Brief for the Appellant
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Last modified
6/24/2010 12:21:26 PM
Creation date
6/11/2010 2:58:18 PM
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Water Supply Protection
Description
Fort Collins and Thorton 86CW371
State
CO
Basin
South Platte
Water Division
1
Date
5/6/1991
Author
Michael D. White, Bruce D. Bernard, Teri L. Petitt
Title
Case No. 90SA514 Opening Brief for the Appellant
Water Supply Pro - Doc Type
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original application did not provide notice to nonparties of the rights claimed in the amended <br />application. Id. at 640. <br />As was true in Bell, the 1988 Application differs so substantially from the 1986 <br />Application that justice requires that the "amendments" may not relate back to the 1986 filing <br />date. Fort Collins was unambiguous as to the type of water right it sought in 1986: an in- <br />stream flow requiring no diversions. The water right sought in 1988 at the Nature Center <br />Diversion Dam was the precise opposite of what Fort Collins unambiguously sought in 1986. No <br />reasonably prudent person, when reading the 1986 Application, could have anticipated or expected <br />that this application, which expressly states that "no points of diversion are proposed," was actually <br />a claim by Fort Collins to divert water at the Nature Center Diversion Dam. Bell, supra,724 P.2d <br />639. As such, it was error for the trial court to relate the filing date of the "amendments" back <br />to the 1986 Application. <br />Moreover, if Fort Collins is not entitled to a 1986 date of appropriation for the <br />Nature Center Diversion Dam, and is instead awarded a 1988 date of appropriation, Fort Collins <br />can not be entitled to benefit from the 1986 filing date. This would place Fort Collins in the <br />highly peculiar situation of being senior to all 600+ water rights filed in Water Division 1 during <br />1987 and 1988, even when those water rights are entitled to dates of appropriation senior to that <br />awarded the Nature Center Diversion Dam. <br />20 Two types of "relation back" may be involved in a water rights application. One involves the relation back of the <br />date of an appropriation to the date on which the first step was taken. Bar 70 Enterprises supra, 703 P.2d at 1306. The <br />other involves relation back of the filing date of an amended application to the filing date of the original application. <br />United States v. Bell, supra, 724 P.2d at 635. <br />21 This is especially true in light of the fact that Fort Collins' original application for in- stream flows was patently <br />unlawful. C.R.S. § 37 -92 See footnote 3 on page 7. Fort Collins should not be allowed to relate back its 1988 <br />Application to an unlawful filing. <br />26 <br />
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