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2011-05-26_ENFORCEMENT - M1977300
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2011-05-26_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:33:50 PM
Creation date
8/10/2011 2:35:59 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
5/26/2011
Doc Name
Reply 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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reclamation measures must bear a reasonable relationship to environmental benefits and that <br />considerations be given to economic reasonableness. None of the Defendants' cases deal with <br />clear language in a "legislative declaration." See Answer Brief at 54. In fact, two of their cases <br />state that, in resolving an issue of statutory interpretation, a court's essential task is to determine <br />and give effect to the intent of the legislature. See Answer Brief at 54 (citing International <br />Truck & Engine Corp. v. Colorado Dep't of Revenue, 155 P.3d 640, 641 (Colo. Ct. App. 2007); <br />Heinicke v. Industrial Claims Appeals Office, 197 P.3d 220, 222 (Colo. Ct. App. 2008)). <br />Courts virtually never reject the legislative declaration when construing statutes. The <br />Defendants cite to Wagner v. Travelers Prop. Cas. Co. of Am., 209 P.3d 1119, 1128 (Colo. Ct. <br />App. 2008), Answer Brief at 46, but that case recognized, relying on a supreme court case, that <br />the legislative declaration at issue in that case was relevant and did establish a standard of care. <br />See Wagner, 209 :P.3d at 1128 (citing Ballow v. PHICO Ins. Co., 875 P.2d 1354, 1362 -63 (Colo. <br />1993)). <br />When Courts have relied on an operative provision instead of a legislative declaration, <br />the operative provision is clear and directly conflicts with a legislative declaration. See Answer <br />Brief at 46 (citing State v. Alvarez, 872 P.2d 1123 (Wash. Ct. App. 1994)) (Court relied on <br />operative statute allowing conviction for an isolated threat and on legislative purpose to prevent <br />harassment, rejecting defendant's reliance on another statement of legislative intent referring to <br />repeated invasions of personal privacy), aff'd, 904 P.2d 754 (Wash. 1995). In the <br />Schwartzwalder Mine matter, the Defendants claim that section 34 -32 -116 is the operative <br />provision. Unlike the facts in Alvarez, section 34 -32 -116 does not conflict with the legislative <br />declaration, because it does not state that the environmental benefits and economic <br />reasonableness of reclamation measures can be disregarded. It therefore is not in conflict with <br />5 <br />
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