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2011-08-11_ENFORCEMENT - M1977300
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2011-08-11_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:36:47 PM
Creation date
10/17/2011 12:01:17 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
Enforcement
Doc Date
8/11/2011
Doc Name
Joint Answer Brief
From
MLRB and DRMS
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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to legislative intent by adopting the construction that best effectuates the purposes underlying the <br />legislative scheme. North Colorado Med. Ctr. Inc., v. Committee on Anticompetitive Conduct, <br />914 P.2d 902, 907 (Colo. 1996). The intent of the General Assembly will prevail over a literal <br />interpretation of a statute that would lead to an absurd result. Henisse 247 P.3d at 579. Courts <br />generally take guidance from the interpretation of a statute made by the agency charged with its <br />administration. See Lucero, 732 P.2d at 646. <br />Here, the Act's plain language authorizes the Board to issue a cease and desist order <br />whenever it determines that any violations of any provision of the Act, Rules, or permit exists. <br />C.R.S. § 34 -32- 124(2) (2010). Cotter's interpretation contradicts with this plain language. <br />Cotter argues that the Board cannot order it to cease and desist the ongoing violations of the Act <br />identified in the August Order, because the phrase "violation of an order" does not appear in <br />section 124(2). See Opening Br. 17. Cotter would read section 124(2) to say that the Board may <br />issue a cease and desist order whenever it finds any violation of any of the provisions of the Act, <br />Rules or Permit exists, unless the violation of the Act, Rules or permit also represents a violation <br />of a standing enforcement order. The Court should not read Cotter's caveat into the statute. See. <br />Healthsouth, 246 P.3d at 951. Cotter's interpretation is unreasonable and undermines the <br />legislative purposes of the Act by allowing an operator to use a prior finding of violation as a <br />shield against further enforcement actions. <br />The plain language of the Act indicates that the General Assembly intended to grant the <br />Board broad discretion to issue cease and desist orders to prevent any violation of any provision <br />of the Act, Rules, or a permit, regardless of whether those violations also amount to a violation <br />of a prior enforcement order. It was not necessary for the General Assembly to include additional <br />12 <br />
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