Connecting You to the Latest in Colorado Law : : Colorado Bar Association Continuing Legal Education
On Thursday, April 18, 2013, the Colorado Court of Appeals issued no published opinions and 36 unpublished opinions.
Neither State Judicial nor the Colorado Bar Association provides case summaries for unpublished appellate opinions. The case announcement sheet is available here.
The Colorado Court of Appeals issued its opinion in Youngs v. Industrial Claim Appeals Office on Thursday, April 11, 2013.
Workers’ Compensation—Worsening Condition—CRS § 8-43-301(2).
In this workers’ compensation action, claimant sought review of a final order of the Industrial Claim Appeals Office (Panel). The order was affirmed.
This was claimant’s third appeal arising from his 2005 workers’ compensation claim. Claimant filed a petition to reopen his claim based on worsening condition and fraud. Employer and its insurer sought to have the fraud claim dismissed for failure to establish the elements to support his request to reopen. The administrative law judge (ALJ) agreed and dismissed the fraud claim. The Industrial Claim Appeals Office (Panel) affirmed the ALJ’s order rejecting claimant’s evidentiary and due process challenges.
A hearing was conducted on the worsening condition claim. The ALJ found employer’s retained independent medical examination (IME) physician’s testimony credible and persuasive, and discredited claimant’s testimony as “implausible, inconsistent, and unsupported by the medical records.” She denied and dismissed his petition to reopen based on worsening condition.
On July 15, 2011, claimant filed his petition to review the ALJ’s order regarding fraud, and on July 18, 2011, he filed his petition regarding worsening condition. The Panel affirmed the latter order and determined it lacked jurisdiction to review the former. Claimant appealed.
The Panel dismissed claimant’s appeal for lack of jurisdiction because it was interlocutory and he had failed to file his petition to review within the applicable twenty-day statutory time period after it became final. On June 24, 2011, ALJ Cain granted partial summary judgment to employer dismissing the petition to review based on fraud, but allowed the remaining claim to proceed (the interlocutory order). On June 27, that order was mailed. On June 29, a hearing on the worsening condition claim was heard by ALJ Jones. On July 15, claimant submitted his petition to review ALJ Cain’s order. On the same day, ALJ Jones denied and dismissed the petition to review based on worsening condition. On July 18, that order was mailed. On July 18, claimant submitted his petition to review only ALJ Jones’s order.
CRS § 8-43-301(2) provides that a petition to review an ALJ order “shall be filed within twenty days after the date of the certificate of mailing of the order.” A party missing this time limit is jurisdictionally barred from obtaining further review of the order.
Claimant argued that he was entitled to automatic review of ALJ Cain’s order when he filed a timely petition for review of ALJ Jones’s order. The Court of Appeals disagreed, finding no authority for such an argument. The Panel correctly determined it had no jurisdiction to review ALJ Cain’s order.
In addition, under CRS § 8-43-301(2), claimant was required to submit a petition to review ALJ Cain’s order after ALJ Jones issued her final order. Filing the petition before ALJ Cain’s interlocutory order became final and appealable does not satisfy the statutory requirement, because it was not within the permissible twenty-day filing period. The Panel therefore had no jurisdiction.
Claimant also challenged the merits of ALJ Jones’s order denying and dismissing his petition to re-open based on worsening condition. ALJ Jones found that claimant failed to establish that his right shoulder pain was related to and caused by his work-related injury to his left shoulder. The Court found the record supported the ALJ’s decision and there was no abuse of discretion in her evidentiary rulings.
Summary and full case available here.
The Colorado Court of Appeals issued its opinion in People v. Lucero Jr. on Thursday, April 11, 2013.
Crim.P. 35(b)—Sentencing—Juvenile—Life Without Parole.
Defendant appealed the trial court’s order denying his Crim.P. 35(b) post-conviction motion seeking reduction of his aggregate eighty-four-year sentence for non-homicide crimes he committed as a juvenile. The order was affirmed.
In 2008, defendant was convicted of conspiracy to commit first-degree murder, attempted first-degree murder, and two counts of second-degree assault. The sentences for all were aggravated as crimes of violence. Defendant was 15 at the time of the incident giving rise to his convictions, but he was charged and tried as an adult.
On appeal, defendant asserted that his sentence violates the Cruel and Unusual Punishments Clause of the federal constitution’s Eighth Amendment and article II, § 20 of the Colorado Constitution. In Graham v. Florida, ___ U.S. ___, 130 S.Ct. 2011 (2010),the U.S. Supreme Court held that juveniles may not be sentenced to life without parole (LWOP) for non-homicide crimes. Defendant argued that his sentence constitutes a de facto LWOP sentence. Defendant will be eligible for parole when he is 57 years old. Because defendant’s sentence provides a meaningful opportunity for release, however, it does not amount to LWOP.
Summary and full case available here.
The Colorado Court of Appeals issued its opinion in People v. Rainer on Thursday, April 11, 2013.
Crim.P. 35(b)—Sentencing—Juvenile—Life Without Parole—Retroactive Application.
Defendant Atorrus Leon Rainer appealed the trial court’s order denying his Crim.P. 35(c) motion asserting that his 112-year sentence was unconstitutional. The order was reversed, defendant’s sentence was vacated, and the case was remanded for resentencing.
In 2000, when he was 17 years old, Rainer burglarized an apartment. During the incident, he shot two victims multiple times with a handgun, seriously injuring them and leaving them in critical condition. Rainer was arrested and was charged and tried as an adult in the district court. Following a jury trial in 2001, the jury found Rainer guilty of two counts of attempted first-degree murder, two counts of first-degree assault, one count of first-degree burglary, one count of aggravated robbery, and sentence enhancement counts for crimes of violence.
On appeal, defendant contended that his sentence violates the Cruel and Unusual Punishments Clause of the federal constitution’s Eighth Amendment. Defendant filed his Crim.P. 35(c) motion after the Supreme Court held in Graham v. Florida, ___ U.S. ___, 130 S.Ct. 2011 (2010), that juveniles may not be sentenced to life without parole (LWOP) for non-homicide crimes. Defendant argued that his 112-year sentence constitutes a de facto LWOP sentence because his life expectancy is between 63.8 years and 72 years (based on Center for Disease Control life expectancy tables).
The rule announced in Grahamis a new substantive rule that must be applied retroactively to all cases involving juvenile offenders under the age of 18 at the time of the offense, including those cases on collateral review. Therefore, the trial court erred when it found that Graham did not retroactively apply to defendant’s sentence.
In addition, although defendant’s motion was untimely, it was based on the new substantive rule of law announced in Graham. Therefore, he established justifiable excuse, his claim was not successive, and his motion was considered on its merits.
Finally, defendant’s aggregate sentence did not offer him, as a juvenile non-homicide offender, a “meaningful opportunity to obtain release” before the end of his expected life span. Thus, it constituted the functional equivalent of a life sentence without parole and was unconstitutional under Grahamand its reasoning.
Summary and full case available here.
The Colorado Court of Appeals issued its opinion in BDG International, Inc. v. Bowers on Thursday, April 11, 2013.
Subject Matter Jurisdiction—Maritime Law—Finality of Judgment—Contract—Duress—Offsetting—Attorney Fees.
Defendants Robert J. Bowers and Auxiliary Graphic Equipment, Inc. (AGE) appealed the judgment entered after a bench trial in favor of plaintiff BDG International, Inc. (BDG). The judgment was affirmed.
AGE purchased printing presses from a seller in Australia for a client located in Colorado. AGE contracted with Fortner Graphic Solutions, Inc. (Fortner) to dismantle the printing presses and transport them to Colorado. Fortner then subcontracted with BDG and other firms to perform its contractual duties. BDG was responsible for transoceanic shipping, and another company was responsible for packing and inland transportation to the client’s site in Colorado. BDG brought this action after defendants failed to pay all costs for inland and ocean freight for the dismantling and shipping of the presses and failed to make payment as required by the agreements to release the resulting liens. The court entered a judgment in favor of BDG and against defendants, jointly and severally.
On appeal, defendants contended that the trial court lacked subject matter jurisdiction over this case, because it involved admiralty or maritime law and exclusive jurisdiction resided with the federal courts. Contrary to defendants’ arguments, however, this action is not in rem in nature; rather, it is a proceeding in personam, because it sought to enforce the contractual agreements against defendants personally and not against the cargo or another type of property of a maritime nature. Accordingly, jurisdiction in this case did not lie exclusively in the federal courts, and the trial court did not lack subject matter jurisdiction to hear this case.
Defendants also contended that the judgment was not final because it does not dispose of the litigation. The judgment entered by the trial court resolved BDG’s and the third-party claim; dismissed the counterclaim with prejudice; and awarded a sum certain for damages, collection costs, and prejudgment interest. Although the trial court provided directions with regard to how the proceeds of any sums recovered by Bowers or AGE should be applied to the judgments they obtained against Fortner in Colorado and Missouri, those directions do not alter the finality of the underlying judgment.
Defendants also contended that the trial court erred in not finding the contracts voidable on the basis of duress. Although defendants may have felt economic pressure to sign the releases to obtain possession of the cargo, the lienholders did not engage in wrongful conduct to coerce payment from defendants.
Defendants further contended that the trial court erred in failing to set off against one another the judgments in this case. Contrary to defendants’ contention, however, the principle of offsetting judgments does not apply, because the judgments are not against the same parties.
BDG collection costs primarily were attorney fees amounting to 40% of the principal due under the agreements signed by defendants. The Court of Appeals therefore ruled that the trial court did not err in awarding BDG collection costs.
Summary and full case available here.
The Colorado Court of Appeals issued its opinion in Larimer County Board of Commissioners v. Colorado Property Tax Administrator on Thursday, April 11, 2013.
Property Tax Exemption—Charitable Use Exemption—Religious Purpose Exemption—Jurisdiction.
In this property tax exemption case, the Young Men’s Christian Association of the Rockies (YMCA) and the Colorado Property Tax Administrator (Administrator) appealed the Board of Assessment Appeals (BAA) orders. The BAA found that the YMCA was not entitled to a charitable use exemption or a religious purposes exemption from property taxes, except for its chapels and religious activity center. The orders were vacated in part, the appeal was dismissed in part, and the case was remanded.
The YMCA owns and operates facilities in Grand and Larimer Counties. The Counties contended that the Court of Appeals did not have jurisdiction to entertain the Administrator’s appeal. Because the BAA did not recommend that the matter was of statewide concern, the Administrator may not appeal. Accordingly, the Court did not have jurisdiction to hear the Administrator’s appeal and, therefore, dismissed it.
The Counties contended that the Court did not have jurisdiction to entertain the YMCA’s appeal. CRS § 39-2-117(5)(b) gives any owner of taxable property in such county the right to appeal the tax administrator’s determination regarding an application for a property tax exemption. Therefore, the Court of Appeals had jurisdiction to hear the YMCA’s appeal from the BAA’s determination.
The YMCA also argued that the BAA erred when it found that the YMCA did not qualify for a religious purposes exemption. The BAA did not discuss the YMCA’s declared purpose in using the properties, whether the YMCA’s activities are in furtherance of the YMCA’s religious purposes, or whether the activities are an integral part of the YMCA’s religious worship. Further, the BAA did not address the YMCA’s declaration of religious purposes contained in its application, the effect of the declaration’s presumed validity, or whether the presumption had been overcome. Because such declarations are presumptive with regard to the religious purposes for which property is used, the BAA did not apply the proper legal standards and, therefore, erred as a matter of law.
The YMCA further contended that the BAA erred when it found that the YMCA did not qualify for a charitable use exemption. Based on the record, the BAA did not properly consider whether the YMCA used the properties solely and exclusively for charitable purposes. Accordingly, the BAA did not apply the correct legal standards and, therefore, erred as a matter of law.
Summary and full case available here.
The Colorado Court of Appeals issued its opinion in People v. Roberts III on Thursday, April 11, 2013.
Uniform Mandatory Disposition of Detainers Act—Speedy Trial.
Defendant appealed the judgments of conviction entered on jury verdicts finding him guilty of violating the Colorado Organized Crime Control Act (COCCA); conspiracy to commit computer crime (two counts); conspiracy to commit theft; conspiracy to commit forgery; computer crime (two counts); theft (four counts); forgery (seventeen counts); and possession of a forged instrument (two counts). The judgments were affirmed.
Defendant contended that his convictions must be vacated because he was not brought to trial within the period allowed by the applicable version of the Uniform Mandatory Disposition of Detainers Act (UMDDA). However, defendant improperly filed his UMDDA request while represented by counsel and improperly served this request. The court and prosecutor did not receive notice of defendant’s UMDDA request until November 10, 2005. Consequently, defendant’s 180-day UMDDA period commenced that day.
Although defendant did not waive his UMDDA rights, the time for bringing defendant to trial was properly extended beyond the May 9, 2006 date as a result of two continuances requested by his attorneys. These continuances, which did not require the personal consent of defendant, were necessary to protect defendant’s constitutional right to effective assistance of counsel, and the length of the continuances were proper, as well. Therefore, there was no violation of defendant’s UMDDA or speedy trial rights.
Summary and full case available here.
On Thursday, April 11, 2013, the Colorado Court of Appeals issued six published opinions and 46 unpublished opinions.
Larimer County Board of Commissioners v. Colorado Property Tax Administrator
BDG International, Inc. v. Bowers
Youngs v. Industrial Claim Appeals Office
The summaries for these cases are forthcoming, courtesy of The Colorado Lawyer.
Neither State Judicial nor the Colorado Bar Association provides case summaries for unpublished appellate opinions. The case announcement sheet is available here.
The Colorado Court of Appeals issued its opinion in United Airlines v. Industrial Claim Appeals Office on Thursday, March 28, 2013.
Workers’ Compensation—$75,000 Statutory Cap for Temporary Total Disability Benefits.
In this workers’ compensation action, United Airlines (employer) sought review of a final order of the Industrial Claim Appeals Office (Panel) affirming the administrative law judge’s (ALJ) denial of employer’s request for reimbursement of temporary total disability (TTD) benefits in excess of the $75,000 statutory cap. The judgment was affirmed.
After claimant sustained a compensable injury in 2007, employer admitted liability for TTD benefits. TTD benefits ceased when claimant was released to return to work in May 2011, by which time she had been paid $99,484.14. Shortly thereafter, a physician performed a division-sponsored independent medical examination and placed claimant at maximum medical improvement (MMI) with a permanent impairment of 5% of the whole person.
Relying on CRS § 8-42-107.5, which caps combined TTD and permanent disability benefits at $75,000 for a claimant whose impairment rating is 25% or less of the whole person, employer sought to recover the $24,483.14 it had paid in excess of the cap. Claimant responded that under CRS § 8-42-105(3), employer was required to continue paying TTD benefits until she was released to work.
The ALJ concluded the cap did not apply as long as claimant was entitled to receive TTD benefits. The Panel agreed and the Court of Appeals affirmed.
The Workers’ Compensation Act (Act) limits the total disability benefits that a claimant whose personal impairment rating is less than 26% may receive. However, the Act provides that benefits continue until one of a number of conditions is met.
Employer argued that benefits paid in excess of the cap must be repaid once claimant’s entitlement to TTD benefits has ended. The Court rejected that contention. Here, claimant received benefits to which she was entitled, and the amount in excess of the cap therefore did not constitute an overpayment.
The Court also found unpersuasive employer’s argument that allowing claimant to keep more than $75,000 in TTD benefits violates equal protection. Equal protection guarantees that similarly situated persons will receive like treatment under the law. Here, no fundamental right is affected or suspect class involved, so a “traditional or rational basis standard of review” applies.
Employer asserted that two classes of claimants are created by the Panel’s decision: those whose benefits will be capped because their benefits had not exceeded the cap when they reached MMI or were released to work, and those whose benefits exceeded the cap before they reached MMI or were released to work. This disparity does not, however, violate equal protection. First, the two classes are not similarly situated. Those claimants who take longer to reach MMI are different from those who take a shorter time. Second, even if they were similarly situated, requiring a claimant to pay back benefits to which she was entitled and needed would create hardships at odds with the purposes of the Act. Proceedings to recover excess payments also could burden the administrative process. These reasons rationally justify the resulting difference in treatment. The order was affirmed.
Summary and full case available here.
The Colorado Court of Appeals issued its opinion in Jordan v. Safeco Insurance Company of America, Inc. on Thursday, March 28, 2013.
Summary Judgment—Underinsured Motorist Benefits.
Plaintiffs Philip and Roberta Jordan appealed the district court’s summary judgment in favor of defendant Safeco Insurance Company of America, Inc. (Safeco) on their claim that Safeco unreasonably denied them underinsured motorist (UIM) benefits. The judgment was affirmed.
In 2009, the Jordans were involved in an automobile accident with J.F., a minor driver. The Jordans were injured and sued J.F. J.F.’s automobile insurance policy covered damages for injury to others up to $100,000 per person or $300,000 per accident. The Jordans settled for $60,000 and $38,500, respectively.
The Jordans sought underinsured motorist (UIM) benefits under their policy with Safeco, asserting that the policy covered all damages unpaid under the settlements, up to the policy limit. Safeco maintained that their UIM coverage would be triggered only if either of them had damages exceeding the $100,000 limit of J.F.’s policy, which neither did.
The Jordans sued Safeco, asserting claims for (1) common law bad faith breach of an insurance contract; (2) unreasonable delay and denial of payment of a claim in violation of CRS §§ 10-3-1115 and -1116; and (3) deceptive trade practice in violation of the Colorado Consumer Protection Act (CCPA). The Jordans moved for summary judgment under their unreasonable delay claims, and Safeco moved for summary judgment on the same claims and the bad faith claim. The parties stipulated that neither could prove damages in excess of $100,000, and the court granted the Jordans’ motion to dismiss their own CCPA claim.
The court granted Safeco’s motion for summary judgment. On appeal, the Jordans challenged only the grant of summary judgment in favor of Safeco under CRS §§ 10-3-1115 and -1116 and conceded that no material facts were disputed.
The Court of Appeals concluded that Safeco’s denial of coverage was permissible under the clear language of the policy, as well as the unambiguous terms of CRS § 10-4-609. The policy language unambiguously provides that payment of UIM benefits are only for damages above the tortfeasor’s insurance policy liability limit. Here, the damages did not exceed those limits.
The Jordans also argued that under CRS § 10-4-609, an insured’s good faith settlement with a tortfeasor necessarily exhausts the tortfeasor’s liability limits. That section, as amended January 1, 2008, requires that UIM coverage “shall be in addition to any legal liability coverage and shall cover the difference, if any, between the amount of the limits of any legal liability coverage and the amount of the damages sustained.” This is plain and unambiguous language. The trigger is the exhaustion of the tortfeasor’s “limits of . . . legal liability coverage.” The judgment was affirmed.
Summary and full case available here.
The Colorado Court of Appeals issued its opinion in Bachelor Gulch Operating Co., LLC v. Board of County Commissioners of Eagle County on Thursday, March 28, 2013.
Tax Abatement/Refund—Subdivision of Property During a Tax Year.
Bachelor Gulch Operating Company, LLC (Bachelor Gulch) appealed the order of the Board of Assessment Appeals (BAA) denying its petition for an abatement or refund of taxes for tax year 2007. The order was affirmed.
Bachelor Gulch owns a substantial portion of the Ritz Carlton Hotel in Eagle County (hotel). For tax year 2007, the Eagle County Assessor assigned the hotel an actual value of approximately $47 million. As of January 1, 2007, which was the assessment date for tax year 2007, the hotel was a single unit for tax assessment purposes. During that year, two new plats were filed that subdivided the original hotel unit, ultimately creating fifty-one separate “child parcels.” Fifty of these were residential condominiums created out of existing hotel rooms. The other was what remained of the hotel after the subdivision (hotel child parcel).
Following the subdivisions, the Assessor allocated the $47 million among the child parcels in proportion to the square footage of each. Approximately $36 million was allocated to the hotel child parcel. Bachelor Gulch petitioned the Board of County Commissioners of Eagle County for an abatement or refund of taxes, which was rejected. Bachelor Gulch then appealed to the BAA, and the appeal was denied.
The Court of Appeals was confronted with the question of what procedure an assessor should use when a property is subdivided during the course of a particular tax year, after the initial valuation and before the next statutory assessment date or a revaluation due to unusual conditions. Colorado statutes provide for the biennial appraisal and valuation of real and personal property for property tax purposes. Bachelor Gulch argued that CRS § 39-5-125(1) applied and the Assessor was required to determine the actual value of the hotel child parcel for 2007. The Court found that the statute unambiguously allows an assessor to conduct a valuation only when it is discovered the taxable property had been omitted from the assessment roll. Because that was not the case here, CRS 39-5-125(1) does not apply.
The Court found no Colorado statute that addresses the question of what to do when a property is subdivided after the initial valuation but before the next assessment date. The State Property Tax Administrator has provided guidance in the Assessor’s Reference Library (ARL). Specifically, the ARL provides that although subdivision and condominium plats can be processed at any time during the year, “the original parcel value and classification must remain the same as assigned to the property on the January 1 assessment date.” In addition, if a project is subdivided after the notice of valuation deadline, the current actual value as of the assessment date is apportioned to the lots or units in the project. Having found that the ARL governs this situation, the Court held that the BAA correctly found that the Assessor complied with its provisions. The order was affirmed.
Summary and full case available here.
The Colorado Court of Appeals issued its opinion in City of Golden v. Aramark Educational Services, LLC on Thursday, March 28, 2013.
Sales Tax Assessment—Summary Judgment.
Plaintiffs, the City of Golden (Golden) and Jeff Hansen, in his official capacity as Golden’s Finance Director, appealed the district court’s summary judgment in favor of defendant, Aramark Education Services, LLC (Aramark). The summary judgment was reversed and the case was remanded to the district court to reinstate the assessment.
The Colorado School of Mines (CSM) and Aramark entered into a Food Services Management Agreement (FSMA) in which they agreed that Aramark would be the exclusive operator of the food service facilities in the CSM Student Center, including the residential dining hall and the Food Court, the I-Club, and other facilities. Aramark operated the Slate Café, the I-Club, the Food Court, Java City, Mines Park Convenience Store, and CSM concessions.
No CSM representative ever handles or takes possession of food either before or after it reaches those facilities. Aramark provided food that generally fell into one of six categories for purposes of this case. Golden levies a sales tax on all sales of tangible property that occur in Golden, including food, unless specifically exempted under the Golden Municipal Code (GMC). Aramark only collects and remits sales tax on CSM campus food sales made with cash, checks, credit, or debit cards. Aramark argued that other sales (as parts of meal plans or added to ID cards) were exempt under the GMC for (1) wholesale sales and (2) direct sales to state institutions “in their governmental capacities only.” Golden disagreed that these were exempt and assessed sales tax.
Aramark protested and received a hearing before Golden’s Finance Director, who upheld the assessment. Aramark appealed to the Colorado Department of Revenue, which reversed. Golden appealed to the Denver District Court and on cross-motions for summary judgment, the district court entered summary judgment in Aramark’s favor. Golden appealed.
The Court of Appeals began by noting the presumption that taxation is the rule and exemption from taxation is the rare exception. All reasonable doubts are resolved against the exemption.
Golden argued that Aramark’s food sales on the CSM campus are wholesale sales. Aramark countered that it sells the food to CSM on a wholesale basis and CSM resells the food to its students, faculty, staff, and guests. The Court held that when individuals purchase food from Aramark-operated food service facilities on CSM’s campus, Aramark is making retail sales to the customers, which are subject to Golden’s sales tax. However, on the issue of when the food is provided as part of a CSM meal plan, a summer conference or summer camp meal plan, or using “Munch Money,” the issue is much closer. However, because Golden’s arguments have sufficient merit to engender reasonable doubts, the issue was resolved in Golden’s favor.
Golden also argued that it was error to conclude that Aramark was exempt from Golden’s sales tax under the GMC’s “governmental capacity” exemption. Such a sale must be a “direct sale” to a department or institution of the State of Colorado. CSM is an institution of the State of Colorado, but it is less clear whether Aramark directly sells its food to CSM. Regardless, the Court concluded that the sales do not qualify because they were not made to CSM in its “governmental capacity only.” CSM has the power to rent, lease, maintain, operate, and purchase buildings and facilities for dining. Aramark does not sell food to CSM in its capacity of doing those things.
The Court additionally found that the sales were made to CSM in both its governmental and proprietary capacities. It was purchasing food in its governmental capacity of educating students, as well as for the private advantage of the faculty and for itself as a legal entity. The summary judgment was reversed and the case was remanded with instructions to reinstate the tax assessment.
Summary and full case available here.
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Solo Tip Tuesday: Change the Outlook Background Color
I use categories in Outlook for a number of reasons. One thing categories allow me to do is look at my calendar and easily tell the difference between a meeting I have to attend, a presentation I’m scheduled to make, and a meeting I need to track but won’t attend. Here’s how to change the background in Outlook. Click here to read more.
