Citizens Project v. Colorado Springs

CourtDistrict Court, D. Colorado
DecidedMarch 25, 2025
Docket1:22-cv-01365
StatusUnknown

This text of Citizens Project v. Colorado Springs (Citizens Project v. Colorado Springs) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Citizens Project v. Colorado Springs, (D. Colo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO District Judge S. Kato Crews

Civil Action No. 1:22-cv-01365-SKC-MDB

CITIZENS PROJECT, COLORADO LATINOS VOTE, LEAGUE OF WOMEN VOTERS OF THE PIKES PEAK REGION, and BLACK/LATINO LEADERSHIP COALITION,

Plaintiffs,

v.

CITY OF COLORADO SPRINGS, and SARAH BALL JOHNSON, in her official capacity as City Clerk,

Defendants.

ORDER DENYING PLAINTIFFS’ MOTION TO ALTER OR AMEND JUDGMENT (DKT. 95)

The above-referenced Motion is fully briefed and now before the Court. See Dkt. 96 (Defendants’ Opposition); Dkt. 97 (Plaintiffs’ Reply). The Motion asks this Court to reconsider its prior Order Dismissing Plaintiffs’ Claim For Lack of Article III Standing and Finding as Moot Defendants’ Motion for Summary Judgment (Dkt. 93). The Court denies the Motion because it is not supported by an intervening change in the controlling law, new evidence previously unavailable, or a need to correct clear error or prevent manifest injustice. STANDARD OF REVIEW A motion under Fed. R. Civ. P. 59(e) is the appropriate vehicle “to correct manifest errors of law or to present newly discovered evidence” bearing on a judgment or other court order. Phelps v. Hamilton, 122 F.3d 1309, 1324 (10th Cir. 1997) (quotations and citation omitted). In the Tenth Circuit, grounds for a motion to reconsider under Rule 59(e) can include “(1) an intervening change in the controlling

law, (2) new evidence previously unavailable, and (3) the need to correct clear error or prevent manifest injustice.” Servants of the Paraclete v. Does, 204 F.3d 1005, 1012 (10th Cir. 2000) (citing Brumark Corp. v. Samson Res. Corp., 57 F.3d 941, 948 (10th Cir. 1995)). Thus, a motion to reconsider is “appropriate where the court has misapprehended the facts, a party’s position, or the controlling law.” Id. These motions are not to be used as a vehicle for “revisit[ing] issues already addressed or advanc[ing] arguments that could have been raised in prior briefing.” Id. (citing Van

Skiver v. United States, 952 F.2d 1241, 1243 (10th Cir. 1991)). A motion for reconsideration “is an extreme remedy to be granted in rare circumstances.” Brumark, 57 F.3d at 944. The decision to grant reconsideration is left to the sound discretion of the district court. Id. ANALYSIS Plaintiffs raise two primary contentions to argue reconsideration of the Court’s

prior order is warranted. First, they contend the Court misapprehended that Defendants were making an affirmative Article III standing argument. Second, the prior order addressed the Supreme Court’s decision in Food & Drug Admin. v. All. for Hippocratic Med., 602 U.S. 367 (2024), which came out after full briefing but before the Court issued the prior order. Plaintiffs argue, “[g]iven FDA’s centrality to the Order’s analysis, reconsideration after fulsome briefing on FDA is appropriate.” Defendants argue reconsideration is not warranted because Plaintiffs present no newly discovered evidence, cite no intervening change in controlling law, and

identify no clear error. They further argue the Court correctly noted the parties’ argument over Article III standing, including that Defendants did not concede Plaintiffs had such standing. And in any event, they argue a party is not excused from establishing standing simply because the opposing party didn’t directly raise the issue. Regarding this Court’s decision to address the Supreme Court’s opinion in All. For Hippocratic Med. in the prior order, Defendants argue the Supreme Court opinion is not an intervening change in controlling law because it came out before the prior

order and merely formed part of the basis for it. 1. Courts are Required to Address Article III Standing, Even Sua Sponte

To be clear, the Court did not pick the issue of Article III standing from the ethereal mist. While the parties may have given short shrift to the importance of the question of Plaintiffs’ Article III standing, Plaintiffs argued in their opposition to Defendants’ motion for summary judgment that they “have both Article III and statutory standing to pursue their claim.” Dkt. 62, p.8. And Defendants made clear in their reply that they did not concede Plaintiffs’ Article III standing. Dkt. 63, ECF p.4, §I(A), ECF p.5 §I(B). The law is clear that a court is required to consider the issue of Article III standing, even sua sponte, and particularly when the record reveals a colorable standing issue. Santa Fe All. for Pub. Health & Safety v. City of Santa Fe, 993 F.3d 802, 813 n.5 (10th Cir. 2021) (“The Alliance contends this court cannot consider

standing relative to its constitutional claims because the district court concluded the Alliance satisfied the standing threshold and the United States did not file a cross- appeal. This argument ignores well-established, black-letter law. The issue of Article III standing implicates federal jurisdiction and is a matter this court must consider sua sponte.”) (italics in original) (citing Rector v. City & Cnty. of Denver, 348 F.3d 935, 942 (10th Cir. 2003); In re Peeples, 880 F.3d 1207, 1212 (10th Cir. 2018) (“Article III standing is jurisdictional; thus, where the record reveals a colorable standing issue,

we have a duty to undertake an independent examination (sua sponte if necessary) of that issue.”) (cleaned up); Rector, 348 F.3d at 942 (“Standing, however, raises jurisdictional questions and we are required to consider the issue sua sponte to ensure that there is an Article III case or controversy before us.”) (cleaned up); PeTA, People for the Ethical Treatment of Animals v. Rasmussen, 298 F.3d 1198, 1202 (10th Cir. 2002) (“Although the question of plaintiffs’ standing was not addressed below,

standing is a jurisdictional issue, and we are obligated to raise the issue sua sponte to ensure that there is an Article III case or controversy.”). The record before the Court on its prior order presented a colorable Article III standing issue, which the parties referenced in their briefing. Indeed, Plaintiffs expressly contended they had Article III standing. Dkt. 62, p.8. And many of the parties’ arguments and proofs concerning statutory standing dovetailed with the issue of Plaintiffs’ Article III standing. See, e.g., Dkt. 63, ECF p.4 (Defendants arguing Plaintiffs’ claimed interest for statutory standing purposes “does not even satisfy

Article III.”); ECF p.5 (arguing “[e]ven if that might support Article III standing— which the City does not concede[.]). The Court does not find Plaintiffs were deprived of an opportunity to argue their Article III standing or to present evidence on the question. The fulsome arguments, briefing, and evidence presented by the parties on the summary judgment record and the statutory-standing question were materially relevant to the issue of Plaintiffs’ Article III standing. Moreover, it was always Plaintiffs’ burden to establish

their Article III standing. Montoya v. Chao, 296 F.3d 952, 955 (10th Cir.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Schiller v. Physicians Resource Group Inc.
342 F.3d 563 (Fifth Circuit, 2003)
Havens Realty Corp. v. Coleman
455 U.S. 363 (Supreme Court, 1982)
Phelps v. Hamilton
122 F.3d 1309 (Tenth Circuit, 1997)
Servants of the Paraclete v. Does
204 F.3d 1005 (Tenth Circuit, 2000)
Montoya v. Chao
296 F.3d 952 (Tenth Circuit, 2002)
Rector v. City & County of Denver
348 F.3d 935 (Tenth Circuit, 2003)
United States Ex Rel. Snapp, Inc. v. Ford Motor Co.
618 F.3d 505 (Sixth Circuit, 2010)
Lee v. McCardle
880 F.3d 1207 (Tenth Circuit, 2018)
Santa Fe Alliance v. City of Santa Fe
993 F.3d 802 (Tenth Circuit, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
Citizens Project v. Colorado Springs, Counsel Stack Legal Research, https://law.counselstack.com/opinion/citizens-project-v-colorado-springs-cod-2025.