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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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to assess civil penalties, the Order requiring. that Cotter pay civil penalties is in excess of <br />statutory jurisdiction and authority and should be set aside. <br />Recognizing that the Board made no explicit finding of a permit violation, the Defendants <br />rely on two insupportable propositions for their claim that the "civil penalties levied against <br />Cotter are within the Board's statutory authority." Answer Brief at 60. First, they contend that <br />the Board "implicitly found Cotter to be in violation of the permit by violating the Act." Id. at <br />61. Second, they contend that the "Board has interpreted section 34 -32- 124(7), C.R.S. to include <br />any violation of the Act or the Rules," and this interpretation is entitled to "great deference." Id. <br />at 61, 64. Both of these propositions fail, as set forth below. <br />A. The Board Made No Finding That Cotter Violated Its Permit. <br />No finding of a permit violation may be implied from the record, including the Board's <br />conclusion that Cotter violated the Act. Except for a passing reference that Cotter "has a <br />reclamation permit," AR:00845, the Order makes no mention of Cotter's permit <br />number M- 1977 -300. AR:00845 -53. Throughout the July 12, 2010 Hearing, the Board gave no <br />consideration to whether Cotter had violated permit number M- 1977 -300. See AR:01034 -49. <br />Nor is there evidence that the Board reviewed or considered Cotter's permit outside the Hearing, <br />14 The Defendants' contention that lain agency's choice of sanction is entitled to <br />deference" is irrelevant to the sanctions issue before this Court. See Answer Brief at 55. Here, <br />Cotter is not asserting that the sanction is too high or low, as alleged in Sheritt v. Rocky <br />Mountain Fire Dist., 205 P.3d 544, 546 -48 (Colo. Ct. App. 2009), or challenging the agency's <br />decision to proceed on certain charges, as alleged in Eddie's Leaf Spring Shop and Towing LLC <br />v. Colorado PUC, 218 P.3d 326, 335 -36 (Colo. 2009), but is challenging the Board's statutory <br />jurisdiction and authority to levy sanctions in any amount in the absence of a finding that Cotter <br />violated its permit. Neither of those cases addressed this issue. The Defendants' third case on <br />this issue, Colorado Real Estate Comm 'n v. Hanegan, 947 P.2d 933 (Colo. 1997), supports <br />Cotter because the court's initial step in addressing the sanctions issue was to determine that the <br />petitioner's "sanction was clearly within the parameters of the Commission's statutory <br />authority." Id. at 935. It follows that without statutory authority, as is true here, no sanction may <br />be imposed. <br />33 <br />
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