HomeMy WebLinkAbout2024CV31043 - Zaffos v. City of Fort Collins - 011 - Response to Motion to Dismiss1
District Court, Larimer, Colorado
201 LaPorte Avenue, Ste 100
Fort Collins, CO 80521
Phone: (970) 498-6100
↑ Court Use Only ↑
LINDA ZAFFOS
Plaintiff,
vs.
THE CITY OF FORT COLLINS
Defendant
Karl W. Hager #52710
VanMeveren Law Group, P.C.
123 N College Avenue, Suite 112
Fort Collins, CO 80524
Telephone (970) 495-9741
Fax (970) 495-6854
Email: khager@vanmeverenlaw.com
Case No.: 2024CV31043
Division: 4C
PLAINTIFF’S RESPONSE TO DEFENDANT CITY OF FORT COLLINS’ MOTION TO
DISMISS
Plaintiff, Linda Zaffos, (“ZAFFOS”) by and through undersigned counsel, VanMeveren
Law Group, P.C., Karl W. Hager appearing, hereby responds to Defendant City of Fort Collins’
(the “CITY”) motion to dismiss and states:
I. INTRODUCTION
The Defendant (the CITY), while undertaking a landscaping project in Old Town, Fort
Collins and maintaining its sidewalk prior to December 20, 2023, removed a tree from a raised,
concrete planter (the PLANTER) situated within the walking path of the southbound sidewalk on
the eastern side of College Avenue. ZAFFOS, while walking on the sidewalk past the Aggie
Theater, a relatively high foot traffic area, caught her foot on the vacant PLANTER and fell,
causing serious bodily injury. The CITY failed to call attention to the hazard after removing the
DATE FILED
January 21, 2025 10:19 AM
FILING ID: 62BB1724AD7CC
CASE NUMBER: 2024CV31043
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tree prior to December 20, 2023, but thereafter removed the PLANTER and replanted the tree akin
to the rest of the sidewalk along College Avenue and throughout Old Town. Plaintiff brings a
Premises Liability claim against the CITY, with pleaded allegations that the CITY waived its
sovereign immunity under C.R.S. § 24-10-106(1)(d)(I). Defendant CITY now moves to dismiss
Plaintiff’s claims on jurisdictional grounds, citing the Colorado Governmental Immunity Act. As
pled in part by Plaintiff, the unused, vacant PLANTER situated in a poorly lit walking path while
being in line for repair/removal with no warnings constituted a dangerous condition under the Act.
As such, this Court has subject matter jurisdiction over the CITY, and the Court should properly
deny the CITY’s motion to dismiss under C.R.C.P. 12(b)(1) and C.R.S. § 24-10-106(1)(d)(I), or,
in the alternative, defer ruling to allow the parties discovery and a Trinity hearing.
II. STANDARD OF REVIEW
1. Motion to Dismiss
A Motion to Dismiss on the basis of sovereign immunity is the same as a Motion to Dismiss
for Lack of Subject Matter Jurisdiction and is decided pursuant to C.R.C.P. 12(b)(1). When
presented with such a Motion, the Court must make factual findings to determine whether the
Court has jurisdiction to hear the case. Trinity Broad. Corp. v. City of Westminster, 848 P.2d 916,
924 (Colo. 1993). The burden of proof is on the plaintiff to prove the government has waived its
immunity. However, this burden “is relatively lenient, as the plaintiff is afforded the reasonable
inferences from [his or her] undisputed evidence.” City and County of Denver v. Dennis, 418 P.3d
489, 494 (Colo. 2018). If the court determines that the plaintiff’s factual allegations regarding the
waiver of immunity are true, then it should award the plaintiff the reasonable inferences from his
or her evidence. Id.
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2. Colorado Governmental Immunity Act (“CGIA”)
A public entity, such as the City of Fort Collins, has sovereign immunity from tort liability
by virtue of the Colorado Governmental Immunity Act (CGIA), C.R.S. § 24 -10-101, et seq. The
immunity conferred by the CGIA is in derogation of the common law. The court is to strictly
construe the immunity provisions of the Act and the waiver provisions are to be broadly construed.
Springer v. City & County of Denver, 13 P.3d 794, 798 (Colo. App. 2000). As a “logical corollary”
of that narrow construction, courts will “broadly construe the CGIA provisions that waive
immunity in the interest of compensating victims of governmental negligence.” Id.
The allegations in the complaint demonstrate that the CITY waived sovereign immunity
under the C.G.I.A. (Complaint in part: ¶ ¶ 7-23, 35-40) As such, the motion to dismiss should be
denied.
C.R.S. § 24-10-106 entitled Immunity and Partial Waiver states:
(1) A public entity shall be immune from liability in all claims for
injury which lie in tort or could lie in tort regardless of whether that
may be the type of action or the form of relief chosen by the claimant
except as provided otherwise in this section. Sovereign immunity is
waived by a public entity in an action for injuries resulting from:
(d)(I) A dangerous condition of a public highway, road, or street
which physically interferes with the movement of traffic on the
paved portion, if paved … of any public highway, road, street, or
sidewalk within the corporate limits of any municipality … which
was designed and intended for public travel or parking thereon….
Whether governmental immunity applies to bar a suit is a question of jurisdiction for the
trial court. Springer v. City and County of Denver, 13 P.3d 794, 798 (Colo. 2000). “The burden of
proof is on the plaintiff to prove that the government waived its immunity, but this burden is
relatively lenient, as the plaintiff is afforded the reasonable inferences from her undisputed
evidence.” Tidwell ex rel. Tidwell v. City and Cty. of Denver, 83 P.3d 75, 85-86 (Colo. 2003).
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“Assessing whether the plaintiff has met this burden requires examining the totality of the
circumstances presented by the undisputed evidence as to whether that particular condition
presented an unreasonable risk.” Maphis v. City of Boulder, 504 P.3d 287, 292 (Colo. 2022) citing
City & Cty. Of Denver v. Dennis, 418 P.3d 489, 494 (Colo. 2018). Grants of immunity by the
C.G.I.A. must be strictly construed. Bertrand v. Board of City Comm’rs, 872 P.2d 223, 227 (Colo.
1994). Because the C.G.I.A. is in derogation of common law, the waiver of immunity is viewed
broadly. Corsentino v. Cordova, 4 P.3d 1082, 1086 (Colo. 2000). See Walton v. State, 968 P.2d
636, 643 (Colo. 1998); City & County of Denver v. Gallegos, 916 P.2d 509, 515 (Colo. 1996).
“[B]ecause tort concepts are naturally subjective, the district court should not resolve the iss ue of
whether the government has committed negligence, the court should only satisfy itself that it has
the ability to hear the case.” City & Cty. Of Denver v. Dennis, 418 P.3d 489, 494 (Colo. 2018). “At
this stage in the proceeding,” this Court should view the case “in the light most favorable to the
[P]laintiff.” Swieckowski by Swieckowski v. City of Fort Collins, 934 P.2d 1380, 1387 (Colo. 1997).
C.R.S. § 24-10-103(1.3) defines dangerous condition as a condition
that constitutes an unreasonable risk which is known to exist or
which in the exercise of reasonable care should have been known to
exist and which condition is proximately caused by the negligent act
. . . of the public entity . . . in constructing or maintaining such
facility.
In St. Vrain Valley Sch. Dist. RE-1J v Loveland, 395 P.3d 751, 755 (Colo. 2017) the
Colorado Supreme Court said:
This court has segregated the CGIA's definition of "dangerous
condition" into a four-factor test. The waiver applies if the injuries
occurred as a result of: (1) the physical condition of the public
facility or the use thereof; (2) which constitutes an unreasonable risk
to the health or safety of the public; (3) which is known to exist or
should have been known to exist in the exercise of reasonable
care; and (4) which condition is "proximately caused by the
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negligent act or omission of the public entity in constructing or
maintaining the facility."
Citing Springer, 13 P.3d at799 (Colo. 2000).
Pursuant to C.R.S. § 24-10-106(1)(d)(l) the CGIA is subject to waiver:
“Sovereign immunity is waived by a public entity in an action for injuries resulting from:
A dangerous condition of a public highway, road, or street which physically interferes with
the movement of traffic on the paved portion, if paved, . . . within the corporate limits of
any municipality . . .”
Pursuant to C.R.S. § 24-10-103 (1.3):
"Dangerous condition" means either a physical condition of a facility or the
use thereof that constitutes an unreasonable risk to the health or safety of
the public, which is known to exist or which in the exercise of reasonable
care should have been known to exist and which condition is proximately
caused by the negligent act or omission of the public entity or public
employee in constructing or maintaining such facility. For the purposes of
this subsection (1.3), a dangerous condition should have been known to
exist if it is established that the condition had existed for such a period and
was of such a nature that, in the exercise of reasonable care, such condition
and its dangerous character should have been discovered.”
The courts in Colorado firmly adopt constructive notice as it relates to waivers of immunity
under the C.G.I.A.. See Walton v. State, 968 P.2d 636, at 645 (Colo. 1998). A public entity may
proximately cause a condition not only by affirmatively creating it, but also by its omission in
failing to reasonably discover and correct the unsafe condition. Springer v. City & County of
Denver, 13 P.3d 794 (Colo. 2000). A dangerous condition should have been known to exist if the
Plaintiff establishes that “the condition had existed for such a period and was of such a nature that,
in the exercise of reasonable care, such condition and its dangerous character should have been
discovered.” C.R.S. § 24-10-103(1.3). The question of a municipality’s knowledge of a dangerous
condition is a question of fact that precludes dismissal on immunity grounds. Luenberger v. City
of Golden, 990 P.2d 1145, 1148 (Colo. App. 1999).
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3. Trinity Hearing Standard
“A trial court may hold an evidentiary hearing to resolve any factual dispute concerning its
jurisdiction under the GIA.” Martinez v. Weld Cty. School Dist. RE-1, 60 P.3d 736, 739 (Colo. App.
2002). “The CGIA requires that once a public entity raises the defense of sovereign immunity, the
court must immediately suspend discovery unrelated to sovereign immunity and decide that issue.
§ 24–10–108, C.R.S. (2017).” City & Cty. Of Denver v. Dennis¸ 418 P.3d 489, 494 (Colo. 2018).
“Any factual dispute upon which the existence of jurisdiction may turn is for the trial court, not
the jury, to determine.” Ferrel v. Colo. Dept. of Corrections, 179 P.3d 178, 183 (Colo. App. 2007).
“[T]rial courts must resolve all issues of immunity before trial through the procedures employed
in Trinity Broadcasting of Denver v. City of Westminster…, and its progeny….” Finnie v. Jefferson
Cty. School Dist. R-1, 79 P.3d 1253, 1259 (Colo. 2003). “If the motion is a factual attack on the
jurisdictional allegations of the complaint . . . the trial court may receive any competent evidence
pertaining to the motion.” Trinity Broad. Corp., 848 P.2d at 924.
In Defendant’s Motion to Dismiss, several material facts are claimed, without the benefit
of Plaintiff having an opportunity to conduct discovery through a Trinity hearing or amend of her
Complaint. Either result should be afforded in lieu of granting Defendant’s Motion to Dismiss at
this stage, and Plaintiff specifically requests such if the Motion to Dismiss cannot be denied.
4. Premises Liability Review Standards
The Colorado Supreme Court has interpreted immunity waiver in the context of the
Premises Liability Act (PLA), C.R.S. § 13-21-115, which governs civil actions against landowners
for injuries occurring on the property. Construing this provision alongside the Colorado
Governmental Immunity Act (CGIA) waiver under C.R.S. § 24-10-106(1)(c), the Supreme Court
has held that, when a public entity provides a public building for public use, it owes a nondelegable
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duty to protect invitees under the PLA from an unreasonable risk to their health and safety due to
a negligent act or omission in constructing or maintaining the facility.
Galef v. Univ. of Colo., 2022 COA 91, ¶ 16, 520 P.3d 184, 188. Regarding the definition of
“dangerous condition”, the fourth element evaluates whether the condition was proximately caused
by the public entity in constructing or maintaining the facility. Id. at ¶ 19. The definition of
“dangerous condition” does not always preclude a waiver for a dangerous condition of a public
building where the public entity’s sole alleged negligent act or omission is a failure to warn of a
hazardous physical condition. Id. at ¶ 24.
III. ARGUMENT
By its Motion to Dismiss, the CITY states that Plaintiff failed to allege a “dangerous
condition,” that the PLANTER itself was not a dangerous condition as a matter of law, and that
lack of signage alone cannot rise to the level of a “dangerous condition.” However, Defendant
injects disputed facts into its argument (Defendant’s Motion to Dismiss pg. 5-6, 9; Declaration of
Ralph Zentz), which should be subject to further discovery by Plaintiff through Trinity procedures.
Notwithstanding, by Plaintiff’s pleading, these arguments are incorrect and misguided and
Defendant’s Motion should be denied, or ruling deferred until further discovery through Trinity
procedures and/or amendment of Plaintiff’s pleading.
1. Plaintiff Properly Alleged the PLANTER Constituted a Dangerous Condition
Defendant improperly argues that Plaintiff failed to allege a dangerous condition as it
applies to waiver of sovereign immunity under the CGIA. C.R.S. § 24-10-103(1.3) defines
dangerous condition as a condition:
that constitutes an unreasonable risk which is known to exist or which in the
exercise of reasonable care should have been known to exist and which condition
is proximately caused by the negligent act . . . of the public entity . . . in constructing
or maintaining such facility.
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In St. Vrain Valley Sch. Dist. RE-1J v Loveland, 395 P.3d 751, 755 (Colo. 2017) the court
acknowledged the segregation of the CGIA's definition of "dangerous condition" into a four-factor
test. The waiver applies if the injuries occurred as a result of: (1) the physical condition of the
public facility or the use thereof; (2) which constitutes an unreasonable risk to the health or safety
of the public; (3) which is known to exist or should have been known to exist in the exerci se of
reasonable care; and (4) which condition is "proximately caused by the negligent act or omission
of the public entity in constructing or maintaining the facility." Citing Springer, 13 P.3d at 799
(Colo. 2000). Plaintiff’s Complaint alleges that ZAFFOS’ injuries occurred as a result of each of
these factors. (in part, Plaintiff’s Complaint ¶ ¶ 7-21; 35-40) “At this stage in the proceeding,”
this Court should view the case “in the light most favorable to the [P]laintiff.” Swieckowski by
Swieckowski v. City of Fort Collins, 934 P.2d 1380, 1387 (Colo. 1997). By Plaintiff’s pleading,
Defendant’s argument fails and the Motion should be denied. Considering disputed factual
information through Defendant’s argument, at a minimum, requires further discovery.
Defendant cites Maphis (which was decided through a Trinity hearing) and Dennis and
compares the PLANTER in this case to a two-inch deviation in a sidewalk that was “largely
imperceptible.” (Defendant Motion to Dismiss pg. 6-7). The CITY then discloses several
photographs in comparison and to describe the character and nature of the PLANTER, which is
far from a “largely imperceptible” two-inch deviation that creates factual disputes warranting
additional discovery.
In Maphis the Colorado Supreme Court affirmed the appellate court’s reversal of the
district court’s decision to dismiss the complaint against Boulder. Maphis, 504 P.3d at 293-94. The
court decided that “based on a totality of the circumstances presented by the undisputed facts” (id.,
at 293), the crack in the sidewalk did not “present a risk that ‘exceeded the bounds of reason.’” Id.,
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at 289, quoting Dennis 418 P.3d at 497. The central undisputed fact that the Maphis Court relied
upon in determining that the risk associated with the crack in the sidewalk was not an unreasonable
risk (i.e., it did not exceed the bounds of reason) was that these types of cracks in sidewalks are
“commonplace throughout Colorado due to the harsh climate and other environmental factors.”
Id., at 293. The court reasoned that in light of some of the purposes of the C.G.I.A. – of protecting
governments from unlimited liability that could disrupt or make prohibitively expensive the
provision of essential services and protecting taxpayers against excessive financial burdens (id., at
291) – the risk was not unreasonable (id., at 293). The court considered that Boulder had a program
to address the cracks (id., at 289-90), had discovered the crack causing the injury (id., at 290), but
that budget limitations necessitated the need for several years to address the cracks (id., at 290).
The court, noting that “we cannot ignore the realities Colorado’s local governments face in trying
to maintain roads and sidewalks”, decided that it is unwilling to impose an impossibly high
standard whereby state and local governments must keep sidewalks like new at all times. Id., at
293, citing Dennis, 418 P.3d at 496. This would significantly increase rather than reduce potential
burdens on taxpayers. Id.
None of these circumstances exist in this case. The unused and empty PLANTER in the
pedestrian walking path on the sidewalk is not commonplace. It’s not commonplace within the
City of Fort Collins in this area either, as nearly every single concrete plante r is now flush with the
sidewalks or removed completely, even housing large trees. The CITY fails to acknowledge this
fact, instead alluding to the length of time that this particular planter was in its current location
prior to December 20, 2023, and that it was remedied after Plaintiff’s injury in response to
complaints. The CITY created the dangerous condition by placing it in its location in the walking
path of pedestrians, especially while not being used to house a tree. It is unknown at this time why
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there was no tree in the PLANTER at the time Plaintiff was injured. It appears, however, that the
PLANTER in question was intended to be “leveled” to sidewalk level at some point prior to
December 20, 2023, as pled by Plaintiff, based on the remedial measures taken by the CITY to
level the PLANTER following Plaintiff’s incident and also based on the rest of these similar
devices in this area of town. There is no information available regarding time or budget limitations
in remediating the unused PLANTER or completing the maintenance regarding replanting the tree.
There are no assertions of any increase in potential burdens on taxpayers. The Maphis Court
determined that monetary considerations made the foreseeable risk, reasonable under the C.G.I.A.
None of these factors exist to make the risk here “reasonable.” Here, the CITY created the
dangerous condition that gave rise to Plaintiff’s injury through its maintenance of the sidewalk;
the chance of injury, damage, or loss was unreasonable, as pled by Plaintiff.
The CITY’s reliance on Dennis is likewise misplaced. In Dennis, the Colorado Supreme
Court reversed the appellate court decision reversing the district court’s decision dismissing the
case against Denver under the C.G.I.A. Dennis 418 P.3d at 498. The court stated that the evidence
showed that the cracks and ruts in the road did not hinder or impede the movement of traffic, that
a third-party driver impeded (cut off) plaintiff (a motorcyclist with a passenger), and that there was
no proof that the road itself caused the accident. Id. The court found that there was no evidence
that the road surface “prevented the motorcycle driver from performing as expected.” Id. The
court also considered the estimated cost to keep roads in Colorado in the condition necessary to
correct the condition at issue (i.e., one billion dollars for roads per year and $360 million per year
for bridges). Id., at 496. Based upon these circumstances and the size of the pothole, the court
decided that “there is a foreseeable risk that the road could cause injury, but that risk is reasonable”
under the C.G.I.A. Id., at 497. The court said that the appellate court must be reversed because it
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“would require state and local governments to keep roads like new at all times or face potential
liability in a tort lawsuit because the road constitutes an unreasonable risk to the health and safety
of the public.” Id., at 496. The Court decided that it was foreseeable that the road condition could
cause injury, “but that risk is inherent in driving on a road that has deteriorated from its original
condition through use.” Id. at 497.
Similar to the comparison of Maphis to this case, none of the material factors leading the
Dennis Court to decide that the risk was reasonable exist in the instant case. In this case, the
PLANTER hindered and impeded the movement of Plaintiff as a pedestrian on the sidewalk, there
was no third-party impeding the Plaintiff, and the PLANTER itself caused the accident. Here,
unlike Dennis, the PLANTER prevented a pedestrian (on the sidewalk) from “performing as
expected.” Also, unlike Dennis, the risk posed by the PLANTER in the sidewalk walking path is
not an inherent risk to pedestrians. It is an unreasonable unique risk, as the PLANTER was not
being used for its intended purpose of protecting and housing a large, visible tree, and instead was
vacant in the walking path with no alerts or warnings as to its presence.
The description given of the PLANTER by Defendant in its Motion to Dismiss
(Defendant’s Motion to Dismiss pg. 7) misrepresents the character and nature of the PLANTER
and lighting conditions on December 20, 2023 (as plead by Plaintiff, Complaint ¶¶ 31, 32). The
photograph described as taken at night, most closely resembling the condition of the PLANTER
on December 20, 2023 (aside from the warning cones and spray paint that were put in place after
Plaintiff sustained her injuries), was taken with night vision and/or flash, illuminating the area.
Defendant then states that the PLANTER was a purposely raised platform intended to hold and
protect a tree, but there was no tree in the PLANTER on December 20, 2023. Defendant further
admits that the PLANTER is located on a “very busy” street and serves an actual purpose of
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obstructing foot traffic, while being located between two dark green items. At the very least, the
facts advanced by Defendant throughout its Motion are disputed and warrant further discovery.
Defendant next argues that the PLANTER’s design was not a “dangerous condition” as a matter
of law, citing design-based rulings.
2. Plaintiff Alleges that Defendant Caused the Dangerous Condition by the Negligent
Act of the CITY in Maintaining the Sidewalk
Defendant next argues that the CITY’s design of the PLANTER did not change and did
not rise to the level of a “dangerous condition.” Relying on Medina and Estate of Grant, the CITY
attempts to make design-based arguments, however the allegations which are scrutinized for
purposes of sovereign immunity here are negligent construction and/or maintenance (in part,
Complaint ¶ 39). Conditions implicating defective maintenance rather than design “develop
subsequent to the initial design and construction.” Medina, 35 P.3d at 456. In Medina, there was
no allegation that the hazardous physical condition developed as a result of the state’s affirmative
actions in undertaking maintenance of the road. Further, a C.G.I.A. definition of “maintenance”
was not in place when Medina was decided. See Galef at ¶ 36, 520 P.3d 184, 192. In contrast,
ZAFFOS alleged that the dangerous condition (PLANTER) was proximately caused by the
negligent act or omission of Defendant in maintaining the roadway. (Complaint ¶ 39), contrary to
Defendant’s argument (Defendant’s Motion to Dismiss pg. 9)
The “initial design,” as indicated by the Declaration of Ralph Zents, was to protect tree
roots of the exiting tree at the time, but there was no tree in the PLANTER on December 20, 2023.
The fact that the CITY removed the tree from the PLANTER prior to December 20, 2023 with no
replacement, warning or otherwise until after Plaintiff was injured, changed the entire utility of the
structure, but not its design. Its presence was nothing more than a hazard until it was removed
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after the tree was taken out, as the Declaration states that the PLANTER was raised to protect tree
roots. This is not the case throughout the same area in the CITY, and the tree was replanted in that
same spot after the PLANTER was leveled. The CITY admits by its Motion to Dismiss that the
PLANTER was removed or made flush with the sidewalk after Plaintiff’s incident, but provides
no facts regarding when the tree was initially removed (as misrepresented in the photographs
provided), or if the PLANTER had a work order or time frame for when it was supposed to be
remedied to its current state. This Declaration further states that similar curbing planters are
currently used around the CITY, but not in Old Town or along College Avenue on December 20,
2023. The PLANTER, located in the walking path of pedestrians, not serving its intended purpose
(i.e. being vacant of any tree) and thereafter being leveled to flush like the majority of every other
tree planter throughout this area of town, all lend to its dangerousness and the unreasonableness
of it through the CITY’s maintenance efforts. Remedial measures taken thereafter would be
admissible as to the feasibility of the maintenance completed on the PLANTER after Plaintiff was
injured (i.e. leveling it and replanting the tree thereafter). See Duggan v. Board of Cty. Commrs.
Of Weld County, 747 P.2d 6. At a minimum, these facts are disputed and warrant further discovery
through the Trinity process. Whether it was part of a pre-determined plan is disputed, as is whether
subcontractors were involved, or the timing of the overall landscaping project with tree removal
and the work orders for the rest of the planters in this area already have been removed or made
flush. It is also unclear at this time who, whether the CITY or a subcontractor, was responsible for
placing the warning/traffic cones on the PLANTER after December 20, 2023 or who painted the
area with bright spray paint after the fact, as represented in the photo provided by Defendant in its
Motion to Dismiss.
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3. Failure to Warn or Lack of Signage Can Constitute a Dangerous Condition
Although Plaintiff did not allege a failure to warn as the sole factor constituting the
PLANTER as a dangerous condition, Defendant’s argument is still inapposite. The CITY argues
in its’ Motion to Dismiss (pg. 10), that the C.G.I.A. does not waive immunity for claims asserting
a failure to warn. Medina v. State, 35 P.3d 442, 449 (Colo. 2001). However, the Galef ruling renders
that statement untrue. In Galef v. Univ. of Colo., 2022 COA 91, 520 P.3d 184, an injured Plaintiff
successfully demonstrated that imperceptibly wet, slippery stairs posed an unreasonable risk to the
health and safety of the public and sufficiently carried his burden to demonstrate that his injuries
resulted from a “dangerous condition of any public building” under the Colorado Governmental
Immunity Act. In so holding, the Court confirmed that the definition of “dangerous condition” can
include a public entity’s failure to warn of a hazardous physical condition in a public building
when: (1) the dangerous condition is not attributable solely to inadequate design; and (2) the public
entity’s duty to warn of a hazard is encompassed within its duty of maintenance. Galef v. Univ. of
Colo., 2022 COA 91, ¶ 24, 520 P.3d 184, 190. “Maintenance” is the act of keeping a facility in the
same general state of repair or efficiency as initially constructed. Id. at, ¶ 36, 520 P.3d 184, 192.
Removing the tree from the PLANTER prior to December 20, 2023 was within the CITY’s
maintenance duties, and the CITY was undertaking maintenance of the PLANTER when it
removed the tree.
As pointed out by the dissent in Maphis, “the failure to call attention to the hazard [],
particularly given how difficult it was to perceive, is relevant to determining whether it was
unreasonably dangerous.” Maphis, 504 P.3d at 295. In this case, the PLANTER being without a
large tree and sticking partially in the walking path of pedestrians, hidden between two dark
objects, is difficult to perceive. Moreover, Defendant fails to acknowledge that the photograph
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disclosed (taken at night) was used with flash and “night vision” lens. Removing the tree, the
purpose of the PLANTER, and failing to call attention to the hazard before thereafter remediating
it completely is highly relevant in the determination of whether or not it is a dangerous condition
under the Act. ZAFFOS alleges that “[l]eaving the PLANTER exposed in the walking path of the
sidewalk on College Avenue with no warnings, additional lighting, pedestrian traffic control
devices or other indicators created a foreseeable chance of injury, damage and/or loss which
exceeded the bounds of reason.” (Complaint ¶ 37). Shortly after this incident occurred, the CITY
placed construction cones around the dangerous condition, painted portions of the sidewalk around
it and then thereafter leveled the planter to flush with the sidewalk. The CITY’s Affidavit provides
no insight into who placed the traffic cones or spray paint, nor any indication as to when or why
the tree was removed prior to December 20, 2023, then replanted after the fact.
IV. CONCLUSION
Based on Plaintiff’s allegations and taking the information in the light most favorable to
the Plaintiff, the Court cannot grant the CITY’s Motion to Dismiss. By Plaintiff’s pleading, the
PLANTER represented a dangerous condition under the Act for which the CITY waived its
sovereign immunity. Plaintiff’s injuries were caused by the dangerous condition alleged and she
should be afforded the opportunity to seek redress for her injuries. This Court should deny the
CITY’s motion to dismiss, or, in the alternative, allow Plaintiff to amend her Complaint following
a Trinity hearing with appropriate discovery in order to decide the question of the CITY’s
sovereign immunity in this case on facts that are determined to be undisputed.
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Dated this 21st day of January 2025. VANMEVEREN LAW GROUP, P.C.
_/s/ Karl W. Hager_____________
Karl W. Hager - #52710
123 North College Avenue, Ste 112
Fort Collins, CO 80524
Telephone: (970) 495-9741
Facsimile: (970) 495-6854
CERTIFICATE OF ELECTRONIC FILING AND SERVICE
I hereby certify that on January 21, 2025 the foregoing Plaintiff’s Response to Defendant
City of Fort Collins’ Motion to Dismiss was filed with the Court and served on all counsel of
record via ICCES according to the Colorado Rules of Civil Procedure.
/s/ Jenn Schossow
Jenn Schossow
Legal Assistant, VanMeveren Law Group, P.C.