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ENFORCE34390
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ENFORCE34390
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Last modified
8/24/2016 7:44:22 PM
Creation date
11/21/2007 2:09:53 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Enforcement
Doc Name
CIVIL ACTION 01-CV-38
Violation No.
CV2000009
Media Type
D
Archive
No
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<br />titat. § 24-4-106(2) in a case involving judicial review of a decision of the Mined T.and R eclamation <br />Board under the Colorado Mined Land Reclamation Act, an entirely different statute front the one <br />at issue here. Nothing in Cheney holds, or even suggests, that the judicial review provision of the <br />Colorado Administrative Procedure Act supereedes the special judicial review provision of the <br />Colorado Surface Coal Mining Reclamation Act. <br />Only by following this Wile announced in Maurer can courts give effect to both general and <br />specific statutory provisions. In this instance, the Legislature obviously intended to s.rbjec*, a broader <br />range ol'Boazd orders and decisions to judicial review than is normally the case. The genera] statute, <br />24-4-106(2), demonstrates that the Legislature knows how to limit judicial review to "final agency <br />action" where it wishes to do so. !n instances where the Legislature has not limited judicial review <br />to "final agency action," but has instead eapressly provided for judicial review of"[aJny order or <br />decision issued by the Board" in recorded proceedings, the statute constitutes a mandate to conduct <br />judicial review regardless of whether the otderurdecision at issue constitutes "final agency action." <br />The Maurer decision establishes beyond question that § 34-33-12g, not § 24-4-106, governs <br />judicial review of Boazd decisions under the Colorado Surface Coal Mining Reclarrtatiott Act. <br />Conseyucntly, Aasin's re] fiance on cast law interpreting the "finality" n;quimrrrent or other provi sines <br />of the APA is completely misplaced. <br />Even if'the judicial review provision of the APA applied here -which it certainly does not <br />-judicial review would be appropriate at this junetutt. This is so hecause the Board order at issue <br />does constitute "final agency action" in the sepazate proceeding that Basin initiated to contest <br />llMCi'sdecisiontovacatetheNOV. The title of theordcritselfcunf~rmsthispointbycharacterizing <br />the action taken as the "Final Board Order in the Matter of the Board's Consideration of an <br />-g- <br />
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