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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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B. To the extent the December 2010 Order is based on alleged statutory <br />violations, the Board acted contrary to law by relying on the identical facts <br />and alleged violations at issue in the August 2010 Order. <br />In their Joint Answer Brief, Defendants contend that the cease and desist order is lawful <br />because it is based on the Board's finding of statutory violations in its earlier August 2010 Order, <br />even though Cotter already had appealed the August 2010 Order before the Board issued its <br />cease and desist order in December 2010. Specifically, Defendants argue the December 2010 <br />Order "sought merely to enforce the August Order [and] did not substantively alter the August <br />Order," and that Cotter's argument "would lead to the result that the Board must issue a cease <br />and desist order immediately upon finding a violation of the Act, Rules, or permit, or forever <br />waive the right to issue a cease and desist order in the future." (Joint Answer Brief at 15, 25) <br />(emphasis in original.) They are wrong on both counts. <br />First, the Board's entering a cease and desist order constitutes a modification of the <br />August 2010 Order. It adds an entirely new remedy that the Division did not seek in the earlier <br />hearing. See AR:0212:7 -9 (Board concurred that August 2010 Order was not a cease and desist <br />order). Thus, the Board's entering a cease and desist order goes beyond "mere enforcement" of <br />the August 2010 Order. As a result, the Board lacked jurisdiction to make this modification to <br />the August 2010 Order after Cotter filed its appeal. Colorado Anti - Discrimination Comm'n v. <br />Continental Airlines, Inc., 355 P.2d 83, 86 (Colo. 1960) ( "[The Colorado Supreme Court] has <br />repeatedly held that an administrative agency is without authority to change, alter or vacate an <br />order while review proceedings are pending in the district court, even as an inferior court is <br />without authority to vacate or modify a judgment after writ of error has issued out of this court <br />directed to such judgment. "). <br />11 <br />
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