Anderson v. Lamm

579 P.2d 620, 195 Colo. 437, 1978 Colo. LEXIS 658
CourtSupreme Court of Colorado
DecidedMay 30, 1978
Docket27941
StatusPublished
Cited by72 cases

This text of 579 P.2d 620 (Anderson v. Lamm) is published on Counsel Stack Legal Research, covering Supreme Court of Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Lamm, 579 P.2d 620, 195 Colo. 437, 1978 Colo. LEXIS 658 (Colo. 1978).

Opinion

MR. JUSTICE LEE

delivered the opinion of the Court.

This case involves vetoes by the Governor of portions of the 1977 general appropriation bill, commonly known as the “Long Bill.” The plaintiff-appellants are eight members of the Fifty-first General Assembly. The defendant-appellees are comprised of the Governor and various state officers. The complaint sought a declaratory judgment that the Governor’s vetoes of nine portions of the Long Bill were invalid because they were improper item vetoes under the veto power given the Governor in Colo. Const. Art. IV, Sec. 12. Preliminary injunctive relief was also requested.

The Denver District Court granted the defendants’ motion to dismiss the complaint. The court held that the complaint failed to state a claim because the portions of the Long Bill vetoed by the Governor were unconstitutional conditions incorporated in the bill in violation of Colo. Const. Art. Ill (separation of powers) and Colo. Const. Art. V, Sec. 32 (regulation of the contents of the Long Bill). The court did not reach the issue of whether the Governor made valid vetoes of these provisions under his item veto power. The court also held that the eight named plaintiffs had standing to sue only as individuals and not on behalf of the general assembly. The court denied the requested injunctive relief.

We affirm the district court’s dismissal of seven of the vetoed portions of the Long Bill for failure to state a claim. However, we hold that the “M” and “C” headnotes to the Long Bill do not violate any constitutional provision and we therefore reverse the district court’s dismissal of these claims and remand for a determination of the propriety of the Governor’s vetoes of them.

*441 I. GENERAL PRINCIPLES

In the present posture of this case, we are not called upon to determine whether the Governor has properly exercised his item veto power. 1 The district court dismissed the lawsuit for failure to state a claim and, therefore, did not reach the veto issue. This court is only presented with the issue of whether the district court was correct in determining that the vetoed portions of the Long Bill were constitutionally invalid, thus precluding the appellants from bringing a challenge to the validity of the Governor’s veto of these provisions.

This court has held, as a general rule, that “subject to constitutional limitations, the General Assembly has plenary or absolute power over appropriations and * * * it may attach conditions upon the expenditure thereof.” MacManus v. Love, 179 Colo. 218, 499 P.2d 609. In the present case, the district court held that the various conditions attached by the general assembly to the Long Bill and vetoed by the Governor violated Colo. Const. Art. III and Colo. Const. Art. V, Sec. 32. Before proceeding to a discussion of each of the vetoed conditions, we will consider the applicability of these two constitutional provisions.

A. Separation of Powers

The district court found that many of the vetoed conditions in the Long Bill violated the doctrine of separation of powers. Article III, the general separation of powers provision in the Colorado Constitution, reads as follows:

“The powers of the government of this state are divided into three distinct departments, — the legislative, executive and judicial; and no person or collection of persons charged with the exercise of powers properly belonging to one of these departments shall exercise any power properly belonging to either of the others, except as in this constitution expressly directed or permitted.”

Although the concept of an absolute separation of functions is clear, it very often proves difficult to determine whether a power being exercised is executive, legislative, or judicial in character. Thus, this court has previously observed that: “The dividing lines between the respective powers are often in crepuscular zones, and, therefore, delineation thereof usually *442 should be on a case-by-case basis.” MacManus v. Love, 179 Colo. 218, 499 P.2d 609.

The executive power of the state is vested in the Governor, who is given the duty to see that the laws are faithfully executed. Colo. Const. Art. IV, Sec. 2; People v. District Court, 29 Colo. 182, 68 P. 242. In order to fulfill this duty to faithfully execute the laws, the executive has the authority to administer the funds appropriated by the legislature for programs enacted by the legislature. MacManus v. Love, supra. In this situation, the Supreme Court of Nebraska has aptly observed that: “It [the legislature] cannot administer the appropriation once it has been made. When the appropriation is made, its work is complete and the executive authority takes over to administer the appropriation to accomplish its purpose, subject to the limitations imposed.” State ex rel. Meyer v. State Board of Equalization and Assessment, 185 Neb. 490, 176 N.W.2d 920. Thus, it follows that the general assembly is not permitted to interfere with the executive’s power to administer appropriated funds, which includes the making of specific staffing and resource allocation decisions.

In addition, the legislature may not attach conditions to a general appropriation bill which purport to reserve to the legislature powers of close supervision that are essentially executive in character. We are confronted with such a legislative encroachment on the executive in the present case with respect to appropriations that are conditioned upon certain reports to or approval from the general assembly’s Joint Budget Committee.

A recent Massachusetts case well-illustrates the problem. In In re Opinion of the Justices to the Governor, _Mass. _, 341 N.E.2d 254, the Supreme Judicial Court had before it a provision in the general appropriation bill which specified that all state-funded jobs which become vacant during the fiscal year shall remain vacant unless there is a “critical need” to fill them. Two committees of the legislature were required to verify the “critical need.” In response to the Governor’s interrogatories, the court found this provision to be unconstitutional. The court observed that the power to determine whether a critical need exists is an executive power to be exercised over the expenditure of appropriated funds, and not one encompassed within the legislative power of appropriation. The court thus held that the provision was an unconstitutional invasion of the executive power. Accord, People v. Tremaine, 252 N.Y. 27, 168 N.E. 817.

B. Contents of the Long Bill

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Bluebook (online)
579 P.2d 620, 195 Colo. 437, 1978 Colo. LEXIS 658, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-lamm-colo-1978.