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2011-08-11_ENFORCEMENT - M1977300
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2011-08-11_ENFORCEMENT - M1977300
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Entry Properties
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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ability to assess unconditional fines, fixed sentences of imprisonment, or both, for conduct that is <br />found to be offensive to the authority and dignity of a court. C.R.C.P. 107(a)(4). Here, the <br />Board simply ordered Cotter to stop violating the August Order. If Cotter violates the cease and <br />desist order, the Board must take the additional step of suing for an injunction to obtain the <br />sanctions available in a contempt proceeding. See C.R.S. § 34- 32- 124(3) (2010). <br />Cotter cites a number of unpersuasive and distinguishable cases for the proposition that <br />an agency violates the separation of powers doctrine when it takes action to enforce its orders. <br />Cotter first cites NLRB v. International Medication Sys., Ltd., 640 F.2d 1110 (9th Cir. 1981), a <br />case that turned on statutory language explicitly stating that the agency could not enforce <br />subpoenas. Id. at 1114. Cotter next cites People v. Swena, 296 P. 271 (Colo. 1931), a case <br />overturning a statute that allowed the Public Utilities Commission to hold parties "in contempt of <br />the commission" and to punish that contempt "in the same manner and to the same extent as <br />contempt is punished by courts of record." Id. at 272. Cotter finally cites Dee Enterprises v. <br />Industrial Claim Appeals Office, 89 P.3d 430 (Colo. App. 2003), a case where the court found no <br />violation of the separation of powers doctrine and observed that "a strict application of the <br />separation of powers doctrine would make the mere existence of an agency unconstitutional." <br />Id. at 433 (internal citations omitted). <br />Cotter incorrectly asserts that judicial review is the "constitutionally proper mechanism <br />for enforcement of an agency order." See Opening Br. 15. Judicial review is certainly available <br />to agencies, but agencies are not mandated to seek judicial involvement every time they attempt <br />to enforce an order. Cotter's argument is inconsistent with the plain language of the APA, which <br />states that, if a court finds an agency action in error, it shall "restrain the enforcement of the order <br />23 <br />
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