HomeMy WebLinkAbout2020CV30580 - City Of Fort Collins V. Board Of County Commissioners Of Larimer County, Colorado And Streetmediagroup, Llc - 001 - Complaint For ReviewDISTRICT COURT, COUNTY OF LARIMER,
COLORADO
Larimer County Justice Center
201 Laporte Avenue, Suite 100
Fort Collins, Colorado 80521-2762
(970) 498-6100
______________________________________________
Plaintiff: THE CITY OF FORT COLLINS,
COLORADO, a municipal corporation,
v.
Defendants: BOARD OF COUNTY COMMISSIONERS
OF LARIMER COUNTY, COLORADO;
STREETMEDIAGROUP, LLC
______________________________________________
Andrew D. Ringel #24762
Hall & Evans, L.L.C.
1001 17th Street, Suite 300
Denver, CO 80202
303-628-3300
Fax: 303-628-3368
ringela@hallevans.com
John R. Duval #10185
Deputy City Attorney
Claire Havelda #36831
Assistant City Attorney
City Attorney’s Office
300 Laporte Avenue
P.O. Box 500
Fort Collins, Colorado 80522
970-221-6652
Fax: 970-221-6327
jduval@fcgov.com
chavelda@fcgov.com
Attorneys for Plaintiff
▲COURT USE ONLY ▲
_________________________
Case Number: 2020CV_____
Division: ___
COMPLAINT FOR REVIEW PURSUANT TO C.R.C.P. 106(a)(4)
DATE FILED: August 25, 2020 3:09 PM
FILING ID: C6398199960F8
CASE NUMBER: 2020CV30580
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Plaintiff City of Fort Collins, Colorado, (the “City”) by and through its attorneys, Andrew
D. Ringel, Esq., of Hall & Evans, L.L.C. and John R. Duval, Esq., Deputy City Attorney, and
Claire Havelda, Esq., Assistant City Attorney, of the Fort Collins City Attorney’s Office, hereby
respectfully submits this Complaint for Review Pursuant to C.R.C.P. 106(a)(4), and alleges as
follows:
INTRODUCTION
1. On July 28, 2020, Defendant Board of County Commissioners of Larimer County,
Colorado (“Board” or “Larimer County”) issued its Findings and Resolution Approving the Street
Media Group Sign Appeal (“Findings and Resolution”) concerning a public hearing it conducted
on June 1, 2020.
2. The Board’s Findings and Resolution concerns a proposed billboard to be erected
by Defendant StreetMediaGroup, LLC (“StreetMediaGroup”) on property located at 4414 East
Harmony Road (“the Property”).
3. The Board’s approval is a quasi-judicial decision subject to review pursuant to
C.R.C.P. 106(a)(4).
4. The City files this action seeking review of the Board’s decision because the
Board’s quasi-judicial decision exceeded its jurisdiction and abused its discretion.
5. The Board exceeded its jurisdiction and abused its discretion in approving the
proposed billboard in multiple ways. The Board failed to properly interpret and apply the Larimer
County Land Use Code (the “LUC”). The Board did not follow the findings and recommendation
of the Larimer County Development Services Team, the staff charged by the Board with
interpreting and applying the LUC (“County Staff”) and failed to provide any alternative analysis,
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rationale, or grounds supported by competent evidence in the record contradicting the analysis,
findings, rationale and conclusion of County Staff. The Board’s interpretation and application of
the LUC are inconsistent with the clear language of the LUC and are not supported by competent
evidence contained in the record before the Board. The Board’s factual findings are not supported
by competent evidence contained in the record before the Board.
PARTIES
6. The City is a home rule city of the State of Colorado organized and existing with
all powers and authority granted to home rule cities in Article XX of the Colorado Constitution.
7. The City’s address is 300 Laporte Avenue, Fort Collins, Colorado, 80521.
8. The Board is the decision maker in this matter and the proper entity to sue pursuant
to C.R.S. § 30-11-105.
9. Larimer County’s address is 200 W. Oak Street, Fort Collins, Colorado 80521.
10. StreetMediaGroup is a Colorado limited liability company.
11. StreetMediaGroup’s address is 161 Saturn Drive, Unit 5A, Fort Collins, Colorado
80525.
JURISDICTION AND VENUE
12. The Board’s Findings and Resolution is a final quasi-judicial decision subject to
review under C.R.C.P. 106(a)(4).
13. This Court has subject matter jurisdiction to review quasi-judicial decisions of the
Board pursuant to C.R.C.P. 106(a)(4).
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14. The City files this Complaint within twenty-eight days of the Board’s approval of
the July 28, 2020, quasi-judicial Findings and Resolution so it is timely pursuant to C.R.C.P.
106(b).
15. Venue before the Court is proper because both the City and Board are in the County
of Larimer, State of Colorado, StreetMediaGroup is located in the County of Larimer, State of
Colorado, and the dispute involves property located in the County of Larimer, State of Colorado.
GENERAL ALLEGATIONS
16. Fort Collins and Larimer County, pursuant to C.R.S. §§ 29-1-203 and 29-20-105,
entered into an Intergovernmental Agreement (Regarding Cooperation on Managing Urban
Development) on June 24, 2008. [See Intergovernmental Agreement (Regarding Cooperation on
Managing Urban Development (“IGA”), attached hereto and incorporated herein as Exhibit A].
17. The IGA was entered into by Fort Collins and Larimer County “for the purposes of
implementing their respective master plans, establishing effective means of joint planning and
management of urbanization within their jurisdictions, assuring that urban development occurs
only as urban level facilities and services are able to be provided, assuring that urban development
that occurs in the unincorporated portion of Larimer County in the vicinity of the City of Fort
Collins is annexed to the City as soon as possible, providing effective means for the appropriate
maintenance of public improvements intended to serve urban development, and assuring that urban
development in the vicinity of the City of Fort Collins does not negatively impact road and storm
drainage systems in unincorporated Larimer County, or appropriately mitigates those negative
impacts;”. [See IGA, at 2, Exhibit A].
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18. To facilitate this goal, the IGA creates the Fort Collins Growth Management Area
(the “GMA”). [See IGA, ¶ 1 and Exhibit 1 attached to IGA, Exhibit A].
19. On January 16, 2017, the IGA was amended to change the GMA. [See Amendment
Number One to Intergovernmental Agreement (Regarding Cooperation on Annexation, Growth
Management and Related Issues), attached hereto and incorporated herein as Exhibit B].
21. The Property is located in the GMA.
22. The Property is also immediately adjacent to property owned by the City.
23. The Property is zoned C—Commercial under the LUC.
24. The Property is a 6.46-acre parcel of land owned by the State Board of Land
Commissioners (the “State Land Board”) and StreetMediaGroup entered into a lease with the State
Land Board on September 4, 2018, to lease 400 square feet of land and 1,000 square feet of aerial
space on the Property for the purpose of placing an outdoor advertising structure or billboard.
25. LUC § 10 imposes regulations on all signs, including billboards, located in any of
Larimer County’s zoning districts. [See LUC § 10.0, attached hereto and incorporated herein as
Exhibit C].
26. The LUC provides: “The purpose of this section is to protect the health, safety and
welfare of the public; to provide the public and property owners with an opportunity for safe and
effective identification of uses and locations within the county; and to avoid clutter and protect
and maintain the visual appearance and property values of the agricultural, residential, business,
commercial and industrial areas of the county.” [See LUC § 10.1, Exhibit C].
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27. On March 24, 2020, StreetMediaGroup filed with Larimer County an Appeal
Request Form for an off-premises electronic billboard to be located on the Property (the
“Billboard”) that is not consistent with LUC § 10 in several respects.
28. The LUC identifies several types of signs that are prohibited in all Larimer County
zoning districts. In pertinent part, the LUC provides:
The following signs are not allowed in any zoning district.
. . .
B. Signs which contain any flashing, rotating, animating or otherwise
moving features. The appearance of electronic or changeable
message signs cannot change more frequently than once every
minute.
. . .
E. Billboards, off-premises signs, except that a home occupation and
an accessory rural occupation may have a temporary, off-premises
directional sign as described in section 10.6.K.
[LUC § 10.5, Exhibit C].
29. StreetMediaGroup’s proposal for its Billboard requested a complete exemption
from Larimer County’s prohibition in LUC § 10.5.E. on billboards and off-premises signs.
30. StreetMediaGroup’s proposal for its Billboard requested a six second change or
dwell time for electronic messages much less than the one minute required by LUC § 10.5.B.
31. The Property is located in a nonresidential zoning district.
32. The LUC provides freestanding signs in nonresidential districts may have a
maximum sign-area size of 90 square feet per side. [See LUC § 10.11.B.2., Exhibit C].
33. The LUC provides freestanding signs in nonresidential districts may have a
maximum height of 18 feet above grade. [See LUC § 10.11.B.2., Exhibit C].
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34. The LUC provides freestanding signs in nonresidential districts must have a setback
measured from the right-of-way of at least 36 feet. [See LUC §§ 10.11.B.2. and 10.B.3., Exhibit
C].
35. StreetMediaGroup’s proposal for its Billboard requested 240 square feet per sign
face in excess of the maximum 90 square feet per side face allowed by the LUC.
36. StreetMediaGroup’s proposal for its Billboard requested a height of 30 feet above
grade in excess of the maximum height of 18 feet above grade allowed by the LUC.
37. StreetMediaGroup’s proposal for its Billboard requested a setback of 30 feet from
the right-of-way less than the 36 feet setback from the right-of-way required by the LUC.
38. On April 29, 2020, City Manager Darin Atteberry wrote Larimer County Manager
Linda Hoffman a letter concerning StreetMediaGroup’s proposal, which letter was submitted to
the Board by County Staff as part of the materials provided to the Board for the June 1, 2020,
appeal hearing. In pertinent part, Mr. Atteberry’s letter to Ms. Hoffman stated:
As we continue to foster and strength our partnership, I would like to again request
your help in responding to some City Council concerns related to electronic
signage. As you know, the City has a history of high standards for commercial
signage. Regulation of signage is of critical importance to our residents, as signage
directly impacts the community’s image and character, and can play a significant
role in defining how Fort Collins is perceived at its entryways.
Larimer County recently received a proposal for a digital billboard near Harmony
Road and I-25, within the City of Fort Collins Growth Management Area (GMA)
and adjacent to City-owned natural areas. The property is almost completely
surrounded by land within the City’s jurisdiction and lies within the Harmony
‘Gateway Area’ which has been subject to an 18-month public process to define a
future vision for how the area will develop over time. In March 2019, the County
received an application similar to the current digital billboard proposal in the same
location. At that time, the City submitted concerns regarding impacts within the
City of Fort Collins GMA. These same concerns apply to the current proposal.
Attached to this letter are details of these concerns and conflicts with the City sign
regulations, relationship to the Arapaho Bend and Eagle View Natural Areas and
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proposed Harmony Corridor Plan Amendments for the Gateway Area, including
design standards, which are pending a 2nd reading with City Council. We encourage
the County to consider the City’s Harmony Gateway Plan when reviewing the
current proposal to support our shared community goals.
[See Letter from Darin Atteberry, April 29, 2020, attached hereto and incorporated herein as
Exhibit D].
39. Proposals deviating “from a standard or requirement imposed by [the LUC]” are
submitted to and considered by the Board. [See LUC § 22.2.1.A.3., attached hereto and
incorporated herein as Exhibit E].
40. The LUC has a specific provision governing the Board’s consideration of an appeal
from the sign regulations in LUC § 10. In its entirety, this provision provides:
To approve an appeal from the applicable requirements in section 10 of this
code the county commissioners must consider the following review criteria and find
that each criterion has been met or determined to be inapplicable:
A. Approval of the appeal is consistent with the purpose and intent of
this code;
B. There are extraordinary or exceptional conditions on the site which
would result in a peculiar or undue hardship on the property owner if section 10 of
this code is strictly enforced;
C. Approval of the appeal would not result in an economic or marketing
advantage over other businesses which have signs which comply with section 10 of
this code.
[See LUC § 22.2.5., Exhibit E].
41. County Staff reviewed the issue and determined StreetMediaGroup’s proposal for
its Billboard did not meet the required criteria under LUC § 22.2.5.
42. With respect to LUC § 22.2.5.A., County Staff concluded the proposal did not meet
this criterion, stating:
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According to Section 10.1 of the Land Use Code, the purposes of the sign
regulations is to “protect the health, safety and welfare of the public; to provide the
public and property owners with an opportunity for safe and effective identification
of uses and locations within the county; and to avoid clutter and protect and
maintain the visual appearance and property values of the agricultural, residential,
business, commercial and industrial areas of the county.”
The intent of the regulations within Section 10 of the Land Use Code is to now
allow off-premises signs, to provide consistent regulation for the allotment of
commercial signage, and to have sign regulations consistent with the regulations
adopted by the City of Fort Collins and the City of Loveland.
Larimer County’s sign regulations were deliberately written to be consistent with
the regulations adopted by the City of Fort Collins and the City of Loveland to
reduce the potential for nonconformities should signs permitted in unincorporated
Larimer County by annexed to one of those cities.
Approval of the appeal would allow this property to have a billboard when new
billboards have been prohibited since June 15, 1992 and would the billboard to be
30 feet tall when the maximum height of a freestanding sign is 18 feet (1.7 times
taller than allowed) with 240 square feet per sign face when a maximum size is 90
square feet per sign face (2.7 times larger than allowed).
In the applicants’ project description, it is noted that removal of the five billboards
from other locations in the Fort Collins area will reduce visual clutter. Staff notes
that as nonconforming signs, the intent is for the five billboards to be removed over
time as their physical condition deteriorates. This would ultimately result in the
removal of the five signs without being replaced by a permanent electronic message
sign.
The City of Fort Collins provided comments (including in attachment G) that
indicate the proposal appeals conflict with their current sign regulations. Their
regulations do not allow new off-p[remises signage, allow one message per minute
on electronic sign displays, do not allow electronic message center displays on pole
signs, and limit pole signs to 18 feet in height and 80 square feet per sign face.
The property is within the Harmony Gateway Area which is a subarea of the
Harmony Corridor Plan. According to the City’s comments, an amendment to the
City’s Harmony Corridor Plan is pending a second reading with the Fort Collins
City Council. The proposed amendment would prohibit billboards and would also
prohibit electronic message center signs on properties within the Harmony
Gateway.
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The City of Fort Collins Natural Areas Department provided comments expressing
concern about the impact of light from the proper billboard on wildlife in the
adjacent Arapahoe Bend Natural Area and nearby Eagle View Natural Area.
The Development Services Team’s assessment is that approval of the appeal would
not be consistent with the intent and purpose of the Land Use Code.
The proposal does not comply with this criterion.
43. With respect to LUC § 22.2.5.B., County Staff concluded the proposal did not meet
this criterion, stating:
No sign permits have previously issued for a freestanding sign on the property.
There have been five permits issued for walls signs which cumulatively are well
under the overall sign allotment for the property.
If Section 10 of the Land Use Code is strictly enforced, the owners of businesses
located on the property would have the ability to obtain permits for a freestanding
sign along the property’s Harmony Road frontage, a freestanding sign along the
property’s I-25 frontage, and permits could be obtained for additional wall signage.
Each of the two freestanding signs could be 18 feet tall with two 90-square foot
sign faces.
The strict enforcement of Section 10 would not allow for the construction of a new
billboard of any size, would not allow for a freestanding sign (on-premises or off-
premises) taller than 18 feet tall or larger than 90 square feet per sign face and
would not allow for an electronic sign with a hold time between messages of less
than 60 seconds.
Staff has not reviewed compelling evidence that there are extraordinary or
exceptional conditions on the site that would result in a peculiar or undue hardship
on the property owner if Section 10 of the Land Use Code is strictly enforced.
Staff finds that the proposal does not comply with this criterion.
44. With respect to LUC § 22.2.5.C., County Staff concluded the proposal did not meet
this criterion, stating:
Approval of the appeal would allow this property to have a billboard when new
billboards are no longer permitted and would allow the billboard to be 30 feet tall
when the maximum height of a freestanding sign is 18 feet (1.7 times taller than
allowed) with 240 square feet per sign face when a maximum size of a freestanding
sign face is 90 square feet (2.7 times larger than allowed). The sign elevation at
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sidewalk level is approximately 16 feet, however the Larimer County Land Use
Code does not contain provisions for elevation-related compensation. It would also
allow the sign at a lesser setback than required by the Code for smaller signs and
would also a hold time of 6 second between messages when a 60 second hold time
is required. The Colorado Department of Transportation’s minimum hold time
between messages is 4 seconds.
Approval of the appeal would provide an economic and marketing advantage over
businesses that comply with Section 10 of the Land Use Code by allowing the
following: increased sign height, increased sign and copy size, presence of
electronic message display, reduced copy hold time, and placement within an area
where off-premises signs are otherwise prohibited.
Staff finds that the proposal does not comply with this criterion.
45. County Staff made the following findings:
The Development Services Team finds that approval of the proposed appeal is not
consistent with the purpose and intent of the Land Use Code, that there are not
extraordinary circumstances on the site which would result in an undue hardship on
the property owner if Section 10 were strictly enforced, and approval of the appeal
would result in an economic or marketing advantage over other businesses which
have signs which comply with Section 10 of the Land Use Code.
46. Based on its analysis of the LUC and findings, County Staff recommended the
Board deny StreetMediaGroup’s sign appeal.
47. The Board considered StreetMediaGroup’s appeal in a noticed public hearing it
conducted on June 1, 2020.
48. County Staff’s analysis, findings and recommendation were provided to the Board
as part of the June 1, 2020, hearing.
49. At the conclusion of the June 1, 2020, public hearing, the Board voted to approve
StreetMediaGroup’s proposal, but did not issue a written decision at that time.
50. On July 6, 2020, Fort Collins City Manager Darin Atteberry and Fort Collins City
Attorney Carrie M. Daggett wrote the Board to ask it to reconsider its vote to approve
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StreetMediaGroup’s proposal for the Billboard. [See Letter from Darin Atteberry and Carrie M.
Daggett, July 6, 2020, attached hereto and incorporated herein as Exhibit F].
51. On July 28, 2020, the Board issued its Findings and Resolution approving in all
respects StreetMediaGroup’s appeal for the Billboard. [See Findings and Resolution, attached
hereto and incorporated herein as Exhibit G].
52. The City now seeks review of the Board’s quasi-judicial decision to approve
StreetMediaGroup’s appeal for the Billboard pursuant to C.R.C.P. 106(a)(4).
FIRST CLAIM FOR RELIEF
(Review Pursuant to C.R.C.P. 106(a)(4))
53. Plaintiff incorporates herein the allegations in paragraphs 1 through 52 above.
54. C.R.C.P. 106(a)(4) permits this Court to review the Board’s quasi-judicial decision
approving StreetMediaGroup’s appeal for the Billboard to determine if the Board exceeded its
jurisdiction or abused its discretion.
55. In approving StreetMediaGroup’s appeal for the Billboard, the Board both
exceeded its jurisdiction and abused its discretion.
56. In approving StreetMediaGroup’s appeal for the Billboard, the Board
misinterpreted and misapplied each of the required criteria provided by LUC § 22.2.5.
57. The Board inappropriately and without a legitimate basis did not follow County
Staff’s interpretation and application of the criteria under LUC § 22.2.5 and the Board failed to
provide any alternative analysis, rationale, or grounds contradicting the analysis, findings,
rationale and conclusion of County Staff.
58. The Board’s failure to follow County Staff’s interpretation and application of the
criteria under LUC § 22.2.5 and failure to provide any alternative analysis, rationale, or grounds
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supported by competent evidence in the record and a reasonable and supported interpretation of
the LUC constitute an abuse of discretion.
59. No competent evidence exists in the record created before the Board on June 1,
2020, and July 28, 2020, concerning the Board’s consideration of StreetMediaGroup’s appeal for
the Billboard (the “Record”) to support the Board’s decision not to follow County Staff’s
interpretation and application of the criteria under LUC § 22.2.5.
60. The Board’s decision not to follow County Staff’s interpretation and application of
the criteria under LUC § 22.2.5 failed to provide any alternative analysis, rationale or grounds
supported by competent evidence in the Record that contradicts the analysis, findings, rationale
and conclusion provided at the June 1, 2020, public hearing by County Staff.
61. The Board’s interpretation and application of LUC § 22.2.5.A. in
StreetMediaGroup’s appeal is not supported by competent evidence in the Record.
62. The Board’s reasoning concerning LUC § 22.2.5.A does not support how the
erection of the Billboard meets the purposes and intent of the LUC and of LUC § 10 in particular.
63. The Board’s reliance on StreetMediaGroup’s representation to take down eight of
its existing non-electronic billboards in Larimer County is misplaced and an abuse of discretion
because taking down these billboards was not made a condition precedent to the Board’s approval
and nothing contained in the Board’s Findings and Resolution requires StreetMediaGroup to
actually remove these existing billboards.
64. The Board’s interpretation, analysis, and conclusion concerning LUC § 22.2.5. is
not consistent with the interpretation and application of this criterion by County Staff and the
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Board failed to provide any alternative analysis, rationale, or grounds supported by competent
evidence in the Record and a reasonable and supported interpretation of the LUC.
65. The Board’s interpretation and application of LUC § 22.2.5.B. is not supported by
competent evidence in the Record.
66. Since LUC § 22.2.5.B. considers only hardships suffered by the “property owner,”
the Board’s reasoning concerning LUC § 22.2.5.B. does not address or support how any peculiar
or undue hardship exists for the State Land Board, the owner of the Property.
67. Any peculiar or undue hardship to StreetMediaGroup as a lessee of a small portion
of the property owner is irrelevant and immaterial for consideration of the criterion in LUC §
22.2.5.B.
68. There is no competent evidence in the Record describing what the hardship would
be to the State Land Board as the property owner or to StreetMediaGroup as a lessee.
69. Conditions on real property typically considered extraordinary or exceptional
conditions causing a peculiar or under hardship for a property owner are physical conditions of the
property such as an odd-shaped lot, unusual topography or other physical conditions unique to the
particular property and not conditions shared by other properties.
70. No specific topographical or physical conditions exist on the Property and no
competent evidence exists in the Record supporting the existence of any such extraordinary or
exceptional conditions on the Property.
71. The specific variances allowed for StreetMediaGroup’s Billboard—exemption
from the prohibition of off-premises billboards; increase in the sign height from a maximum of 18
feet above grade to 30 feet above grade; increase in the sign face from 90 square feet to 240 square
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feet; the change in the setback requirement from 36 feet to 30 feet; and the reduction of one-minute
message frequency to six seconds—are not linked with any competent evidence in the Record
before the Board to any specific topographical or physical condition existing on the Property to
meet this criterion.
72. StreetMediaGroup’s rationale for these variances from the requirements of LUC §
10 are not linked to any specific topographical or physical conditions on the Property, but rather
are conditions shared by other properties in the area.
73. The Board’s interpretation of LUC § 22.2.5.C. is not supported by competent
evidence in the Record.
74. The Board’s reasoning concerning LUC § 22.2.5.C. does not support how approval
of the Billboard would not result in an economic or marketing disadvantage over other business
which have signs which comply with LUC § 10.
75. The Board’s interpretation and application of LUC § 22.2.5.C. is inconsistent with
its plain language.
76. No competent evidence exists in the Record to support any conclusion concerning
any new advertising opportunity for specific small businesses or non-profits from the erection of
StreetMediaGroup’s Billboard.
77. No competent evidence exists in the Record that other businesses with off-premises
billboards that strictly comply with LUC § 10 will not suffer an economic or marketing
disadvantage in comparison to StreetMediaGroup’s Billboard.
78. The Board’s Findings and Resolution are not supported by competent evidence in
the Record before the Board.
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79. The Board’s interpretation and application of LUC § 10 and LUC § 22.2.5. in its
Findings and Resolution constitute an abuse of discretion.
80. The Board’s Findings and Resolution constitute a quasi-judicial decision in which
the Board exceeded its jurisdiction and abused its discretion and there is no plain, speedy, and
adequate remedy otherwise provided by law.
PRAYER FOR RELIEF
WHEREFORE, for the foregoing reasons, Plaintiff City of Fort Collins, Colorado
respectfully requests the Court grant the following relief against Defendants the Board of County
Commissioners of Larimer County, Colorado, and StreetMediaGroup, LLC:
A. Find and declare the Board exceeded its jurisdiction and abused its discretion in its
Findings and Resolution approving the proposed Billboard;
B. Find and declare the Board’s Findings and Resolution approving the proposed
Billboard are not supported by competent evidence contained in the Record before the Board;
C. Find and declare the Board’s interpretation and application of the LUC in the
Findings and Resolution constitute the Board exceeding its jurisdiction and abusing its discretion;
D. Award the City its attorney fees and costs pursuant to Colorado law; and
E. All other and further relief as the Court deems just and appropriate under the
circumstances.
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Dated this 25th day of August, 2020.
Respectfully submitted,
/s/ Andrew D. Ringel________________
Andrew D. Ringel #24762
Hall & Evans, L.L.C.
1001 17th Street, Suite 300
Denver, CO 80202
303-628-3300
Fax: 303-628-3368
ringela@hallevans.com
and
John R. Duval #10185
Deputy City Attorney
Claire Havelda #36831
Assistant City Attorney
City Attorney’s Office
300 Laporte Avenue
P.O. Box 500
Fort Collins, Colorado 80522
970-221-6652
Fax: 970-221-6327
jduval@fcgov.com
chavelda@fcgov.com
ATTORNEYS FOR PLAINTIFF
THE CITY OF FORT COLLINS
COLORADO
Address of Plaintiff:
The City of Fort Collins
300 Laporte Avenue
P.O. Box 500
Fort Collins, Colorado 80522