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2011-06-14_ENFORCEMENT - M1977300
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2011-06-14_ENFORCEMENT - M1977300
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Entry Properties
Last modified
8/24/2016 4:34:28 PM
Creation date
8/10/2011 2:35:47 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
6/14/2011
Doc Name
Opening Brief of Plaintiff Cotter Corporation (N.S.L.)
From
Cotter Corporation
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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agency erroneously interpreted the law." Stell v. Boulder Cnty. Dep't of Social Services, 92 P.3d <br />910, 916 (Colo. 2004). <br />"[A]n agency's determination of its own jurisdiction is subject to de novo review by a <br />court." Hawes v. Colorado Div. of Ins., 65 P.3d 1008, 1015 (Colo. 2003). As a matter of <br />constitutional law, an administrative agency cannot decide the limits of its statutory authority <br />because that is a judicial function. Id. ( "A cardinal principle of American constitutionalism is <br />that those who are limited by law should not be empowered to decide on the meaning of the <br />limitation: foxes should not guard henhouses. ") (quoting Cass R. Sunstein, After the Rights <br />Revolution: Reconceiving the Regulatory State 224 (1990)). <br />II. The Board's December 2010 Order Exceeds Its Statutory Authority. <br />A. As an Administrative Agency, the Board's Power Is Limited to That Granted <br />by Its Enabling Statute. <br />The Board, as an administrative agency, is bound to comply strictly with its enabling <br />statute. Adams v. Colorado Dep't of Social Services, 824 P.2d 83, 86 (Colo. Ct. App. 1991). <br />The authority to regulate does not include the authority to legislate. Id. Therefore, unless <br />expressly or impliedly authorized by statute, administrative rules and regulations are without <br />force and legal effect if they add to, change, modify, or conflict with an existing statute. Id. A <br />regulation that is inconsistent with or contrary to a statute is void and of no effect. Miller <br />International Inc. v. State Dep't of Revenue, 646 P.2d 341, 344 (Colo. 1982) In attempting to <br />regulate in accordance with a statute, a regulation may not supersede the statute. Big Top, Inc. v. <br />Schooley, 368 P.2d 201, 204 (Colo. 1962). <br />9 <br />
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