Campaign Integrity Watchdog v. Colorado Secretary of State

2025 COA 18
CourtColorado Court of Appeals
DecidedFebruary 20, 2025
Docket24CA0128
StatusPublished

This text of 2025 COA 18 (Campaign Integrity Watchdog v. Colorado Secretary of State) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Campaign Integrity Watchdog v. Colorado Secretary of State, 2025 COA 18 (Colo. Ct. App. 2025).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY February 20, 2025

2025COA18

No. 24CA0128, Campaign Integrity Watchdog v. Colorado Secretary of State — Election Law — Fair Campaign Practices Act — Campaign Finance Complaints — Investigation and Enforcement

The division concludes that the campaign and political finance

enforcement mechanism in section 1-45-111.7, C.R.S. 2024, is

facially constitutional. The division determines that once the

United States District Court for the District of Colorado held that

section 9(2)(a) of article XXVIII of the Colorado Constitution was

facially unconstitutional in Holland v. Williams, 457 F. Supp. 3d

979 (D. Colo. 2018), and the Secretary could no longer act under

that constitutional provision, the subsequent enactment of a new

enforcement mechanism was necessary under section 9(1)(b) of

article XXVIII. The division holds that the plaintiff failed to prove that the subsequently enacted section 1-45-111.7 violates

principles of separation of powers or due process.

Next, the division addresses the district court’s dismissal of

the plaintiff’s complaint filed under section 1-45-111.7 against the

defendant political committee. First, the division reverses that part

of the district court’s order holding that the committee was not

required to file mandatory reports under the applicable campaign

and political finance laws. However, the division affirms the portion

of the order dismissing the plaintiff’s allegation that the committee

failed to maintain an active registered agent. COLORADO COURT OF APPEALS 2025COA18

Court of Appeals No. 24CA0128 City and County of Denver District Court No. 22CV666 Honorable Kandace C. Gerdes, Judge

Campaign Integrity Watchdog LLC, a Colorado corporation,

Plaintiff-Appellant,

v.

Colorado Secretary of State, Jena Griswold, in her official capacity,

Defendant-Appellee.

ORDER AFFIRMED IN PART AND REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division III Opinion by JUDGE TAUBMAN* Tow and Bernard*, JJ., concur

Announced February 20, 2025

Matthew Arnold, Denver, Colorado, for Plaintiff-Appellant

Philip J. Weiser, Attorney General, Peter G. Baumann, Assistant Solicitor General, Denver, Colorado, for Defendant-Appellee

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2024. ¶1 In this campaign finance law dispute, plaintiff, Campaign

Integrity Watchdog LLC (Watchdog), appeals the district court’s

order affirming the Secretary of State’s dismissal of Watchdog’s

complaint against Alliance for a Safe and Independent Woodmen

Hills (Alliance). Because we conclude that the campaign finance

constitutional and agree that Alliance had a registered agent, we

affirm the order in part. Because we agree with Watchdog’s

contention that the Secretary erred by dismissing its allegation that

Alliance had failed to file reports required by Colorado’s campaign

finance laws, we reverse the order in part and remand the case for

further proceedings.

I. Background

A. Watchdog and Alliance’s Extensive History of Campaign Finance Disputes

¶2 Alliance is a “political committee” under article XXVIII of the

Colorado Constitution.1 Colo. Const. art. XXVII, § 2(12).

1 As the supreme court did in previous litigation between these

parties, we will also “treat Alliance as a ‘political committee’ because that is how it is registered and its status is not at issue in this case.” Campaign Integrity Watchdog v. All. for a Safe & Indep. Woodmen Hills, 2018 CO 7, ¶ 22, 409 P.3d 357, 361 (Watchdog I).

1 ¶3 Watchdog is a Colorado limited liability company that

frequently pursues private enforcement of campaign and political

finance matters.

¶4 When Alliance campaigned against a candidate in a local

election in 2014, Watchdog filed its first complaint against Alliance

with the Secretary of State under article XXVIII, section 9(2)(a), of

the Colorado Constitution. This complaint marked the beginning of

a decade-long adversarial relationship between Watchdog and

Alliance that has been well documented in prior litigation. See

generally Campaign Integrity Watchdog v. All. for a Safe & Indep.

Woodmen Hills, 2018 CO 7, 409 P.3d 357 (Watchdog I); All. for a

Safe & Indep. Woodmen Hills v. Campaign Integrity Watchdog, LLC,

2019 CO 76, 450 P.3d 282 (Watchdog II). However, because not all

the parties’ litigation history is relevant here, we only discuss the

pertinent aspects of their prior litigation.

B. Colorado’s Changing Campaign and Political Finance Enforcement Scheme

¶5 Article XXVIII of the Colorado Constitution governs campaign

and political finance. Article XXVIII was proposed by a citizens’

initiative as “Amendment 27” and adopted by popular vote in 2002.

2 Colo. Ethics Watch v. Senate Majority Fund, LLC, 2012 CO 12, ¶ 17,

269 P.3d 1248, 1253. In adopting article XXVIII, the electorate

declared

that large campaign contributions to political candidates create the potential for corruption and the appearance of corruption; that large campaign contributions made to influence election outcomes allow wealthy individuals, corporations, and special interest groups to exercise a disproportionate level of influence over the political process; . . . that because of the use of early voting in Colorado[,] timely notice of independent expenditures is essential for informing the electorate; that in recent years the advent of significant spending on electioneering communications, as defined herein, has frustrated the purpose of existing campaign finance requirements; that independent research has demonstrated that the vast majority of televised electioneering communications goes beyond issue discussion to express electoral advocacy; . . . and that the interests of the public are best served by limiting campaign contributions, establishing campaign spending limits, providing for full and timely disclosure of campaign contributions, independent expenditures, and funding of electioneering communications, and strong enforcement of campaign finance requirements.

Colo. Const. art. XXVIII, § 1 (emphasis added). Article XXVIII vests

the Secretary with authority to administer and enforce its

provisions, though of course not without limit. Colo. Const. art.

3 XXVIII, § 9(1)(b) (“The secretary of state shall . . . [p]romulgate

rules . . . as may be necessary to administer and enforce . . . this

article.”); Hanlen v. Gessler, 2014 CO 24, ¶ 35, 333 P.3d 41, 49

(“[T]he Secretary lacks authority to promulgate rules that conflict

with statutory provisions.”).

¶6 The Fair Campaign Practices Act (the Act) also governs

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Cite This Page — Counsel Stack

Bluebook (online)
2025 COA 18, Counsel Stack Legal Research, https://law.counselstack.com/opinion/campaign-integrity-watchdog-v-colorado-secretary-of-state-coloctapp-2025.