CO2 Committee v. Montezuma County

CourtCourt of Appeals for the Tenth Circuit
DecidedJuly 28, 2025
Docket24-1337
StatusUnpublished

This text of CO2 Committee v. Montezuma County (CO2 Committee v. Montezuma County) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CO2 Committee v. Montezuma County, (10th Cir. 2025).

Opinion

Appellate Case: 24-1337 Document: 40-1 Date Filed: 07/28/2025 Page: 1 FILED United States Court of Appeals Tenth Circuit UNITED STATES COURT OF APPEALS July 28, 2025 FOR THE TENTH CIRCUIT _________________________________ Christopher M. Wolpert Clerk of Court CO2 COMMITTEE, INC.,

Plaintiff - Appellant,

v. No. 24-1337 (D.C. No. 1:23-CV-02457-CNS-NRN) MONTEZUMA COUNTY; (D. Colo.) MONTEZUMA COUNTY BOARD OF COUNTY COMMISSIONERS; MONTEZUMA COUNTY ASSESSOR,

Defendants - Appellees. _________________________________

ORDER AND JUDGMENT * _________________________________

Before BACHARACH, PHILLIPS, and FEDERICO, Circuit Judges. _________________________________

This is a case challenging a retroactive tax assessment imposed on

corporate entities in Colorado. Plaintiff CO2 Committee, Inc. (the

Committee) filed suit against Montezuma County, the Montezuma County

Board of County Commissioners, and the Montezuma County Assessor

(together, the County). The Committee sought damages, declaratory relief,

* This order and judgment is not binding precedent, except under the

doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Federal Rule of Appellate Procedure 32.1 and Tenth Circuit Rule 32.1. Appellate Case: 24-1337 Document: 40-1 Date Filed: 07/28/2025 Page: 2

and injunctive relief under 42 U.S.C. § 1983. The Committee alleged that it

was improperly subjected to a retroactive tax assessment by the County and

did not receive proper notice of this assessment. The district court, however,

ruled that it lacked subject matter jurisdiction to hear the case. It granted

the County’s motion to dismiss, citing the Tax Injunction Act of 1937 (TIA),

28 U.S.C. § 1341, which precludes federal courts from adjudicating

challenges to state taxes.

The Committee argues on appeal that it was never provided a remedy

or an opportunity to pursue its case in state court because its case in state

court was dismissed for lack of standing. It further alleges that the district

court failed to accept as true all allegations in its complaint. After full

consideration of these arguments, we affirm the district court’s dismissal of

the complaint.

I

The Committee filed this case in the United States District Court for

the District of Colorado on the heels of more than a decade of previous court

and state agency proceedings. The Committee’s lawsuit is based on a

2 Appellate Case: 24-1337 Document: 40-1 Date Filed: 07/28/2025 Page: 3

retroactive tax assessment imposed on the Committee’s unit operator, 1

Kinder Morgan. The tax assessment arose from activities within the

McElmo Dome Unit, a large deposit of carbon dioxide in Montezuma

County, Colorado. The Committee alleges that its members own

approximately an 11 percent interest in the McElmo Dome Unit, and that

Kinder Morgan owns approximately 44 percent.

In an audit of the 2008 tax year, the County determined that Kinder

Morgan’s unit owed over $2 million in unpaid taxes based on a related party

transaction conducted by Kinder Morgan. 2 The Committee alleges that

Kinder Morgan then allocated the retroactive tax assessment to all

nonoperating fractional interest owners, even though they played no role in

1 A “unit” is “a consolidation of working interests that extract resources from a single geological reservoir.” Colorado Prop. Tax Adm’r v. CO2 Comm., Inc., 527 P.3d 371, 373 (Colo. 2023) (internal quotation marks omitted). Units are created to make the extraction process more efficient and coordinated, and although “the fractional interests in a unit may be owned by many entities, a single unit operator often handles the day-to-day operations.” Id.

2 As to the related party transaction, the Committee alleges that the

County imposed a retroactive assessment because “Kinder Morgan, as a working interest owner, had impermissibly deducted transportation costs related to the Cortez Pipeline Company, a partnership in which Kinder Morgan was a 50% owner, thereby reducing its taxable income.” Op. Br. at 11. The Committee further alleges that “[t]he additional taxes were not attributable to the Committee’s members, who were unrelated to the Cortez Pipeline Company and permitted to deduct the full transportation costs.” Id. 3 Appellate Case: 24-1337 Document: 40-1 Date Filed: 07/28/2025 Page: 4

the related party transaction conducted by Kinder Morgan, and thus the

Committee should not be held responsible to pay the additional taxes. It

further alleges that it did not receive notice of the retroactive tax

assessment imposed by the County against the unit’s nonoperating

fractional interest owners.

Both the Committee and Kinder Morgan pursued state administrative

challenges and then filed Colorado state court lawsuits protesting the $2

million retroactive tax assessment. Both of their cases reached the Colorado

Supreme Court, which ruled first against Kinder Morgan and then against

the Committee. In rejecting Kinder Morgan’s challenge, the Colorado

Supreme Court held the retroactive tax assessment was lawful. Kinder

Morgan CO2 Co. v. Montezuma Cnty. Bd. of Comm’rs, 396 P.3d 657, 667–68

(Colo. 2017).

The Committee claims that it was only after this ruling, in November

2017, that it first became aware of the retroactive tax being imposed on its

unit by the County, and that Kinder Morgan “encouraged” it to file suit

challenging the tax imposed on Kinder Morgan, the unit operator. Op. Br.

at 11–12.

The Committee filed a lawsuit in Colorado state court on October 1,

2018, seeking to challenge the retroactive assessment imposed on Kinder

Morgan. Id. at 12–13. The Committee’s state court challenge failed,

4 Appellate Case: 24-1337 Document: 40-1 Date Filed: 07/28/2025 Page: 5

however, because the Colorado Supreme Court held that “nonoperating

fractional interest owners in an oil and gas unit” do not “have standing to

independently challenge a retroactive assessment and property tax

increase.” Colorado Prop. Tax Adm’r v. CO2 Comm., Inc., 527 P.3d 371, 375

(Colo. 2023). Instead, Colorado law “creates a representative system for oil

and gas leaseholds and lands, in which the unit operator serves as the sole

taxpayer.” Id. at 378. Only the unit operator prepares and files an “Annual

Statement.” Id. at 373. Using the Annual Statement, the county tax

assessor then calculates the property taxes owed by the unit, and “[u]nit

operators are responsible for collecting these taxes from all of the

nonoperating fractional interest owners and remitting the total amount

owed to the county treasurer.” Id. at 374.

Because the Committee is not a “taxpayer” under these circumstances

and is not listed on the Annual Statement filed by the unit operator, the

Colorado Supreme Court held that “the only entity that receives notice” of

the valuation or retroactive tax assessment under Colorado law “is the unit

operator.” Id. at 378.

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

Related

Rosewell v. LaSalle National Bank
450 U.S. 503 (Supreme Court, 1981)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Marcus v. Kansas, Department of Revenue
170 F.3d 1305 (Tenth Circuit, 1999)
E.F.W. v. St. Stephen's Indian High School
264 F.3d 1297 (Tenth Circuit, 2001)
Brooks v. Nance
801 F.2d 1237 (Tenth Circuit, 1986)
Norman Quincy Wright v. Jerry McClain Director
835 F.2d 143 (Sixth Circuit, 1987)
Khalik v. United Air Lines
671 F.3d 1188 (Tenth Circuit, 2012)
Folio v. City Of Clarksburg
134 F.3d 1211 (Fourth Circuit, 1998)
Peterson v. Martinez
707 F.3d 1197 (Tenth Circuit, 2013)
Liebhardt v. Department of Revenue
229 P.2d 655 (Supreme Court of Colorado, 1951)
Salzer v. SSM Health Care of Oklahoma Inc.
762 F.3d 1130 (Tenth Circuit, 2014)
Siloam Springs Hotel, L.L.C. v. Century Sur. Co.
906 F.3d 926 (Tenth Circuit, 2018)
COLORADO PROPERTY TAX ADMINISTRATOR v. CO2 COMMITTEE, INC.
527 P.3d 371 (Supreme Court of Colorado, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
CO2 Committee v. Montezuma County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/co2-committee-v-montezuma-county-ca10-2025.