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2012-05-04_GENERAL DOCUMENTS - C1981008
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2012-05-04_GENERAL DOCUMENTS - C1981008
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Last modified
8/24/2016 4:57:19 PM
Creation date
2/21/2014 9:53:00 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
General Documents
Doc Date
5/4/2012
Doc Name
Defendants Reply Brief in Support of Motion to Dismiss for Lack of Subject Matter Jurs 2010 CV 367
From
Christopher Kamper, Craig R. Carver, Carver, Schwarz, McNab & Baily, LLC
To
District Court Montrose County Colorado
Permit Index Doc Type
General Correspondence
Email Name
DAB
Media Type
D
Archive
No
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D. Federal Law and Colorado Law Are Different. <br />Third, plaintiffs attempt to rely upon an Illinois case applying the federal SMCRA <br />statute. See, Response Brief at 5, citing Ginn v. Consolidated Coal, 437 N.E.2d 793, 794 (Ill. <br />App. 1982). This case is inapposite. It arose before Illinois adopted its own state coal mining <br />program. That adoption rendered SMCRA no longer the law of Illinois. Ginn is therefore not <br />even good law in its state of origin. <br />Moreover, the opinion states that the only administrative action taken was issuance of a <br />notice of violation. That is not an adverse decision the plaintiff in that case could have corrected <br />through an appeal, as is true of the instant case. Further, because Ginn arose under SMCRA and <br />the relevant notice of violation was issued by the federal OSM and not the state permit authority, <br />a different exhaustion analysis is required by SMCRA itself. "Action of the State regulatory <br />authority pursuant to an approved State program shall be subject to judicial review by a court of <br />competent jurisdiction in accordance with State law." 30 U.S.C. § 1276(e) (emphasis added). <br />This means that Colorado standards of exhaustion control this case, under standards far stricter <br />than federal law. Under Colorado law, remedies must be exhausted if they are "available" and <br />"complete, adequate, and speedy." City & County of Denver v. United Air Lines, 8 P.3d 1206, <br />1212 (Colo. 2000). Under federal law, it depends on specific language of the agency enabling <br />statute, and such considerations as whether that language is mandatory or permissive. E.g., <br />Darby v. Cisneros, 509 U.S. 137, 144 — 148 (1993) (defining when exhaustion is required under <br />federal law). <br />Finally, there is another significant difference between federal and state law. The federal <br />statute expressly states that the "availability of review established in this subsection shall not be <br />construed to limit the operations of rights established in Section 520 [30 USCS § 1270] [the <br />0 <br />
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