My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
2011-06-14_ENFORCEMENT - M1977300
DRMS
>
Day Forward
>
Enforcement
>
Minerals
>
M1977300
>
2011-06-14_ENFORCEMENT - M1977300
Metadata
Thumbnails
Annotations
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
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
33
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
The plain language of the Act does not grant authority to the Board to issue a cease -and- <br />desist order for the violation of a previous Board order. Therefore, the Board exceeded its <br />statutory authority in entering a cease - and - desist order, and the December 10, 2010 Order should <br />be set aside. <br />D. To the Extent the December 2010 Order Is Based on Alleged Statutory <br />Violations, the Board Acted Contrary to Law by Relying on the Identical <br />Facts and Alleged Violations at Issue in the August 2010 Order. <br />The Division and Board apparently contend that the cease - and - desist order is lawful <br />because it is based on a statutory violation as determined by the Board in its earlier August 2010 <br />Order. The Division's counsel stated at the Hearing: <br />MS. LINDEN: I mean, the board in July found violations of the <br />act, set corrective actions. Cotter has failed to comply with them. <br />And under this — under 34 -32 -105 in conjunction with 124, you <br />have the ability to enforce your board orders. <br />AR:0276:14 -19. One of the Board members picked up and continued the same argument: <br />MS. GREEN: But for me I think just personally it all collapses <br />into the fact that the order was issued because we did find a <br />violation of the act and the regulation, and we said, Here's some <br />steps to get you out of that, and those steps — if those steps were <br />not taken, which we would have to still discuss, it would seem to <br />me that in the end what we would be doing is imposing a cease - <br />and- desist order to enforce the statute, because that's the <br />underlying issue and, I think, you know, the kind of tortured <br />reading that you'd have to read to say that's not possible. <br />AR:0289:11 -22. <br />Essentially, the Division and Board argue they can use the December 2010 Order to add a <br />cease - and - desist remedy to address the alleged facts and statutory violations in the August 2010 <br />Order. The Board, however, lacked jurisdiction to grant additional relief in the form of a cease - <br />and- desist order based on the same facts and alleged statutory violations that were the subject of <br />18 <br />
The URL can be used to link to this page
Your browser does not support the video tag.