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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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Fifth, even if this Court resorts to interpretive rules of statutory construction, which it <br />may not do, the Defendants' contentions are without merit. Colo. Rev. Stat. § 34 -32 -124 is titled <br />"Failure to comply with conditions of order, permit, or regulation." This title fails to address the <br />circumstances in which the Board may assess civil penalties. It also does not mention any failure <br />to comply with the "Act." Section 34- 32 -124's title, therefore, cannot possibly "strongly <br />suggest[]" that "the General Assembly intended to authorize the Board to levy civil penalties" for <br />a violation of the Act. See Answer Brief at 63. <br />Defendants' remaining efforts at divining legislative intent (assuming such efforts are <br />even permissible) do not support the Defendants' interpretation of Colo. Rev. Stat. § 34 -32- <br />124(7). They contend that "[a]11 other parts of section 124 allow actions for violations of the <br />Act, a permit, and regulations," implying that section 34- 32- 124(7) must do the same. Answer <br />Brief at 63. The Defendants' assertion is incorrect, as section 34- 32- 124(6)(a) says nothing <br />about violations of the Act and regulations, and authorizes the Board to "suspend, modify, or <br />revoke" a permit if, and only if, the Board determines, after hearing, that "a violation of a permit <br />provision has occurred." (Emphasis added.) Accordingly, rather than supporting the <br />Defendants, section 34- 32- 124(6)(a) supports Cotter. <br />The Defendants also find no support in their claim that "[c]onstruing subsection (7) <br />separately from the remainder of section 124 would lead to an absurd result.i Answer Brief at <br />16 The cases that the Defendants cite on this issue do not assist their defense. They cite <br />GLN Compliance Group, Inc. v. Aviation Manual Solutions, LLC, 203 P.3d 595, 598 (Colo. Ct. <br />App. 2008), for the proposition that a court will not "pursue a statutory construction that would <br />lead to an unreasonable or absurd conclusion." See Answer Brief at 62. However, in that case, <br />the court applied the statutory language as written even though the result "may seem inflexible." <br />203 P.3d at 602. Likewise, they cite Rodriguez v. Schutt, 914 P.2d at 925, for the proposition <br />that "[c]ourts should avoid construing statutes to have an absurd or unconstitutional result." <br />Answer Brief at 62. However, as was true in GLN, the court declined to apply the principle on <br />38 <br />
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