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2012-04-27_GENERAL DOCUMENTS - C1981008
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2012-04-27_GENERAL DOCUMENTS - C1981008
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Last modified
8/24/2016 4:56:56 PM
Creation date
2/21/2014 9:53:41 AM
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DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
General Documents
Doc Date
4/27/2012
Doc Name
Plaintiffs Response to Defendants Motion to Dismiss for Lack of Subject Matter Jurisd 2010 CV 367
From
Christopher G. McAnany Matthew A. Montgomery Dufford, Waldeck, Milburn & Krohn, LLP
To
District Court, Montrose County Colorado
Permit Index Doc Type
General Correspondence
Email Name
DAB
Media Type
D
Archive
No
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The doctrine of exhaustion of administrative remedies does not apply where a statutory <br />scheme preserves common law claims not covered by statute. Brooke v. Restaurant. Servs., Inc., <br />906 P.2d 66, 71 (Colo. 1995)(no exhaustion of remedies required under anti- discrimination act, <br />which preserved common law tort claims). Second, the doctrine does not apply if the agency's <br />jurisdiction does not empower it to grant the type of relief the plaintiff seeks. Ryals v. St. Mary - <br />Corwin Regional Med. Or., 10 P.3d 654, 662 (Colo. 2000)(`Because [plaintiff) was not required <br />to file his claims with the [administrative agency], no state administrative remedy existed for him <br />to exhaust. "). Finally, the exhaustion requirement does not apply when the administrative <br />agency lacks authority to consider the question presented. Janssen v. Denver Career Services <br />Board, 998 P.2d 9, 12 (Colo. 1999)( "The doctrine [of exhaustion remedies] has no application <br />when: (1) the administrative agency does not have authority to pass on every question raised; and <br />(2) there is grave doubt that the administrative agency has the authority to pass on the question <br />raised. "). <br />Here, the thrust of Plaintiffs' Complaint is that WFC improperly mined their property by <br />stripping and removing topsoil from the leased premises. First Amended Complaint (FAC) ¶ 13, <br />17, 18. These soil handling practices will result in diminution of farmable acreage, topography <br />which is incompatible with irrigated agriculture, and less favorable soil conditions in terms of <br />salt content, rock content, and the like. FAC ¶ 19, 20, 21.1 Among other things, the Coal <br />Mining Lease between the parties provides that WFC, the Lessee, <br />"shall reclaim the property so that the Property is approximately in the same condition as <br />when Lessee entered the Property (i.e. a farmable condition). This includes returning the <br />land to cropland to grow alfalfa or row crops, leaving land flat enough for irrigation and <br />1 WFC fails to articulate any elevated pleading standard which might apply to this action. Plaintiffs maintain that <br />their FAC adequately stated the factual basis for their claims, as required by C.R.C.P. 8, which requires merely a <br />concise statement of the basis for relief. To the extent that this Court deems otherwise, Plaintiffs are prepared to <br />amend their complaint to more specifically delineate the factual basis for their claims. <br />
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