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1979-04-25_ENFORCEMENT - M1978352
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1979-04-25_ENFORCEMENT - M1978352
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Last modified
8/11/2022 2:33:37 PM
Creation date
11/21/2007 12:29:59 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1978352
IBM Index Class Name
Enforcement
Doc Date
4/25/1979
Doc Name
MEMORANDUM BRIEF IN SUPPORT OF DEFENDANTS MOTION TO DISMISS OR IN ALTERNATIVE FOR SUMMARY JUDGMENT
Media Type
D
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No
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DRMS Re-OCR
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Signifies Re-OCR Process Performed
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• <br /> P <br /> Nor are Plaintiffs relieved of their obligation to <br /> ~exhaust administrative remedies by their claim of improper notice. <br /> In the first place, such claims are belied by the numerous con- <br /> tacts, weeks in advance of the March 1 Board meeting, between <br /> Plaintiffs' counsel and representatives of the Division. [Heffner <br /> Affidavit, 9[$9-11. ] It is undisputed that Plaintiffs had numerous <br /> opportunities to request an adjudicatory hearing, but ignored all <br /> of them. <br /> Particularly relevant to the question of exhaustion in <br /> the context of alleged notice defects is the case of Citizens Comm. <br /> for Fair Property Taxation v. Warner, 127 Colo. 121, 254 P. 2d 1005 <br /> (1953 ) . In Warner, a group of taxpayers brought an original <br /> proceeding in the Supreme Court challenging a real property tax <br /> assessment. The Supreme Court dismissed the action for failure to <br /> exhaust administrative remedies which were, "a required precedent <br /> to maintenance of a court action" . Citizens Comm. v. Warner, <br /> supra, 254 P. 2d 1005, 1013. In response to the petitioners' claim <br /> that they were excused from the exhaustion requirement because <br /> notice of administrative proceedings was irregular, the Court <br /> noted that the alleged notice defect did not prejudice plaintiffs <br /> ability to participate in the administrative proceeding. Simi- <br /> larly in this case, the undisputed facts reveal that Plaintiffs' <br /> opportunity to request a hearing was in no way prejudiced by an <br /> alleged notice defect. <br /> This case presents a classic example of failure to ex- <br /> haust administrative remedies. It further demonstrates the unten- <br /> able position that is created for the Court, the administrative <br /> agency and the interested parties when a complainant fails to ex- <br /> haust administrative remedies, thereby resulting in an inadequate <br /> record for judicial review. Plaintiffs' failure to exhaust readily <br /> available administrative remedies which would have permitted ade- <br /> quate fact finding and record development thus requires the <br /> dismissal of their action. See, Heron v. City of Denver, supra, <br /> 283 P. 2d 647. <br /> -10- <br />
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