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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
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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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ignores the fact that the December 2010 Order also imposed civil penalties based upon the <br />Board's finding that Cotter had violated the August 2010 Order. <br />Where, as here, the legislature has not given the Board specific authority to impose civil <br />penalties for violation of an administrative order, the Court should set aside the December 2010 <br />Order. See People v. Swena, 296 P. 271, 272 (Colo. 1931) ( "The power to punish for contempt <br />is a judicial power within the meaning of the Constitution. It belongs exclusively to the courts, <br />except in cases where the Constitution confers such power upon such other body. "). <br />II. The Board Also Exceeded Its Authority by Entering a Cease and Desist Order <br />Based on an Alleged Violation of a Prior Board Order. <br />A. The Act does not include the violation of a prior order as grounds for a cease <br />and desist order. <br />The Board's cease and desist order suffers from the same legal deficiencies as the <br />imposition of civil penalties. The Act limits the Board's authority to issue a cease and desist <br />order to the "violation of any provisions of this article or of any notice, permit or regulation." <br />Colo. Rev. Stat. § 34- 32- 124(2)(a). As in the case of civil penalties, the legislature <br />conspicuously omitted "a violation of an order" in section 124(2)(a) in contrast with the broader <br />scope of section 124(1). Again, the Court must interpret this omission as a decision by the <br />legislature to limit the Board's authority. See In Re Water Rights, 221 P.3d at 419; Specialty <br />Rests., 231 P.3d at 397. <br />6 Defendants concede that the purpose of imposing fines was "to compel Cotter to <br />comply with the corrective actions...." (Joint Answer Brief at 8.) <br />10 <br />
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