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1999-04-01_GENERAL DOCUMENTS - C1981017 (2)
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1999-04-01_GENERAL DOCUMENTS - C1981017 (2)
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Last modified
3/16/2021 7:17:41 PM
Creation date
5/3/2012 9:33:45 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
4/1/1999
Doc Name
DMG motion to dismiss certain claims
From
US District Court
To
Mid-Continent Resources, Inc. & DMG
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
Tags
DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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framework for determining whether the asserted legal basis for a claim--whether constitutional, <br /> statutory, or otherwise--can properly be understood as granting [the plaintiff] a right to judicial <br /> relief." O'Bryant v. Public Utilities Comm'n, 778 P.2d 648, 652 (Colo. 1989). <br /> "[A] court should not render a declaratory judgment unless it will fully and finally resolve <br /> the uncertainty and controversy as to all parties with a substantial interest in the matter that could <br /> be affected by the judgment." People ex rel. Inter-Church Temperance Movement v. Baker, 133 <br /> Colo. 398, 297 P.2d 273, 277-78 (1956), cited in Constitution Assocs. v. New Hampshire Ins. <br /> Co., 930 P.2d 556, 561 (Colo. 1996)(emphasis in original). <br /> MCR's sixth claim is for declaratory judgment regarding"the rights, responsibilities, and <br /> liabilities of MCR with respect to . . ." alleged sedimentation caused by the Division's <br /> reclamation activities. Amended Third-Parry Complaint at p. 9. Unstated,but underlying <br /> MCR's sixth claim, is MCR's fear of enforcement action by the Health Department. The courts <br /> have often addressed declaratory judgments in the context of threatened regulatory enforcement, <br /> and have held that"[t]he injury-in-fact element of standing is established when the allegations of <br /> the complaint, along with any other evidence submitted on the issue of standing, establishes that <br /> the regulatory scheme threatens to cause injury to the plaintiffs present or imminent activities." <br /> O'Bryant at 653. Here,there is no allegation of imminent enforcement by the Health Department <br /> -- in fact, there could be no such enforcement, nor threat thereof, because of the many <br /> uncertainties set forth in MCR's Amended Third Party Complaint, ¶¶ 57 and 58.3 MCR's sixth <br /> 3 The Division concedes that MCR need not violate its Water Quality Control Division permit"in order to secure the <br /> adjudication of uncertain legal rights." Community Tele-Communications. Inc.v. Heather Corp.,677 P.2d 330,334 <br /> (Colo. 1984). However,in order to show declaratory judgment standing MCR must" . . . demonstrate that there is <br /> an existing legal controversy that can be effectively resolved by a declaratory judgment, and not a mere possibility <br /> of a future legal dispute over some issue." Bowen/Edwards at 1053,citing Three Bells Ranch Assocs. v. Cache La <br /> Poudre Water Users Ass'n,758 P.2d 164, 168(Colo. 1988). ZD <br /> 17 <br />
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