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2011-09-19_ENFORCEMENT - M1977300
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2011-09-19_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:43:14 PM
Creation date
10/17/2011 12:01:27 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
9/19/2011
Doc Name
Reply Brief of Plaintiff Cotter Corporation
From
Cotter Corporation
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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"A regulation may not modify or contravene an existing statute." Cartwright v. State Bd. <br />of Accountancy, 796 P.2d 51, 53 (Colo. Ct. App. 1990). "Any regulation that is inconsistent with <br />or contrary to a statute is void." Rigmaiden v. Colorado Dep't of Health Care Policy & <br />Financing, 155 P.3d 498, 504 (Colo. Ct. App. 2006); see Colo. Rev. Stat. § 24- 4- 103(8)(a) <br />( "Any rule or amendment to an existing rule issued by any agency ... which conflicts with a <br />statute shall be void. "). "Courts have a duty to invalidate administrative regulations which <br />conflict with the design of a statute." Cartwright, 796 P.2d at 53. As explained in one of the <br />cases upon which Defendants rely (see Joint Answer Brief at 12) "administrative regulations are <br />not absolute rules. They may not conflict with the design of an Act, and when they do, the court <br />has a duty to invalidate them." Travelers Indemnity Co. v. Barnes, 552 P.2d 300, 303 (Colo. <br />1976) (affirming trial court's finding that regulation was invalid). <br />Here, 2 Colo. Code Regs. § 407 -1, Rule 3.3.2(2)(b) is inconsistent with, and contrary to, <br />Colo. Rev. Stat. § 34- 32- 124(7), because it authorizes civil penalties for violations of the Act <br />when the Act provides no such authority. Accordingly, this Court may not defer to <br />Rule 3.3.2(2)(b) and should determine that it is void and unenforceable. <br />3. The Division did not prove a violation of Cotter's permit. <br />Defendants contend that, even if their strained statutory interpretation is rejected, the <br />Court should uphold the December 2010 Order because "the record clearly indicates that the <br />3 The Act specifies that "[a]11 rules and regulations shall be subject to the provisions of <br />section 24 -4 -103,, C.R.S." Colo. Rev. Stat. § 34 -32- 108(2). <br />4 Defendants' reliance on Lucero v. Climax Molybdenum Co., 732 P.2d 642, 645 -46 <br />(Colo. 1987) is misplaced (see Joint Answer Brief at 11 -12, 14) as no claim was made in that <br />case that the agency's rule and order conflicted with the plain language of the statute. <br />6 <br />
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