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2012-03-30_GENERAL DOCUMENTS - C1981008
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2012-03-30_GENERAL DOCUMENTS - C1981008
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Last modified
8/24/2016 4:55:41 PM
Creation date
2/21/2014 9:54:09 AM
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DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
General Documents
Doc Date
3/30/2012
Doc Name
Defendants Brief in Support of Motion to Dismiss for Lack of Subject Matter Jurisd 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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Walden Truck Line, Inc. v. Denver -Fort Collins Freight Serv., Inc., 399 P.2d 242 (Colo. 1965). <br />Thus, "[w]hen administrative remedies are provided by statute or ordinance, the statutory <br />procedure must be followed if the matter complained of is within the jurisdiction of the <br />administrative authority." Moss, 250 P.3d 739, 743; Janssen v. Denver Career Serv. Bd., 998 <br />P.2d 9, 12 (Colo. App. 1999). "If the parties fail to satisfy the exhaustion requirement, the <br />district court is without jurisdiction to hear the action." State of Colorado v. Golden's Concrete <br />Co., 962 P.2d 919, 922 (Colo. 1998); see also CRS § 24- 4- 106(2) ( "Final agency action under <br />this or any other law shall be subject to judicial review as provided in this section. ") <br />Colorado courts recognize two, and only two limited exceptions to the foregoing: <br />Exhaustion is not necessary ... when it is "clear beyond a reasonable doubt that <br />further administrative review by the agency would be futile because the agency <br />will not provide the relief requested." Exhaustion is also unnecessary ... when <br />the matters in controversy are matters of law that the agency lacks the authority or <br />capacity to determine, such as constitutional issues. <br />City & County of Denver v. United Air Lines, 8 P.3d 1206, 1213 (Colo. 2000) (citations omitted); <br />see also, Thomas v. Federal Deposit Ins. Corp., 255 P.3d 1073, 1077 (Colo. 2011). Moreover, <br />the converse is also true. The need for application of the rule requiring exhaustion <br />of remedies becomes more persuasive when, as here, the matter in controversy <br />raises the precise questions which are within the expertise of the administrative <br />agency, and are of the very nature the agency was designed to resolve. <br />Downey v. Department of Revenue, 653 P.2d 72, 74 (Colo. App. 1982). <br />Finally, the form in which the allegations are stated in the complaint is irrelevant to the <br />exhaustion analysis. See, Golden's Concrete, 962 P.2d 919, 922 n.6 (dismissed claims sounding <br />in waiver, estoppel, res judicata, statute of limitations, and laches, as well as a request for <br />declaratory judgment); United Airlines, 8 P.3d 1206, 1210 (dismissed action for declaratory <br />
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