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Case No. 98CV5863 Plaintiffs' Opening Breif December 1998
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Case No. 98CV5863 Plaintiffs' Opening Breif December 1998
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Water Supply Protection
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Case No. 98CV5863 Plaintiffs' Opening Breif December 1998
State
CO
Date
12/9/1998
Author
Hall, Vonda G.
Title
Case No. 98CV5863 Plaintiffs' Opening Breif December 1998
Water Supply Pro - Doc Type
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Professional Engineering (PS) series and the Environmental <br />Protection Specialist series and the Physical Science /Research <br />series." (Rec., Vol. XV, p. 7295, 9[8.) <br />The Director's Decision was arbitrary and capricious, contrary <br />to law, and unsupported by substantial evidence on the record, and <br />should be reversed. <br />1. The Director's affirmance was arbitrary and capricious. <br />Arbitrary and capricious action by a government agency has <br />been defined by the Colorado Supreme Court as follows: <br />Capricious or arbitrary exercise of discretion by an <br />administrative board can arise in only three ways, <br />- namely: (a)-- By- neglecting or refusing to use reasonable <br />diligence and care to procure such evidence as it is by <br />law authorized to consider in exercising the discretion <br />vested in it. (b) By failing to give candid and honest <br />consideration of the evidence before it on which it is <br />authorized to act in exercising its discretion. (c) By <br />exercising its discretion in such manner after a <br />consideration of evidence before it as clearly to <br />indicate that its action is based on conclusions from the <br />evidence such that reasonable men fairly and honestly <br />considering the evidence must reach contrary conclusions. <br />Van De Vegt v. Board of Commissioners at 705. <br />A failure or refusal to consider relevant evidence is <br />arbitrary and capricious. Kerr v. Board of County Commissioners, <br />460 P.2d 235, 237 (Colo. 1969). Acting in bad faith in order to <br />further one's own secret agenda is also arbitrary and capricious. <br />See Buddy and Lloyd's Store v. City Council, 337 P.2d 389, 391 -392 <br />(Colo. 1959)( "The wide discretion which we have repeatedly held is <br />E <br />
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