Garcia v. Jefferson County

CourtColorado Court of Appeals
DecidedOctober 30, 2025
Docket24CA1386
StatusUnpublished

This text of Garcia v. Jefferson County (Garcia v. Jefferson County) 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
Garcia v. Jefferson County, (Colo. Ct. App. 2025).

Opinion

24CA1386 Garcia v Jefferson County 10-30-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA1386 Jefferson County District Court No. 24CV30089 Honorable Andrew C. Poland, Judge Honorable Meegan A. Miloud, Judge

Joanne Garcia,

Plaintiff-Appellant,

v.

Jefferson County R-1 School District,

Defendant-Appellee.

JUDGMENT AND ORDER AFFIRMED AND CASE REMANDED WITH DIRECTIONS

Division VII Opinion by JUDGE TOW Lum and Moultrie, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced October 30, 2025

Bachus & Schanker, LLC, Scot C. Kreider, Corey A. Holton, Denver, Colorado, for Plaintiff-Appellant

Caplan and Earnest LLC, Justin H. Miller, Boulder, Colorado, for Defendant- Appellee ¶1 Plaintiff, Joanne Garcia, appeals the district court’s judgment

dismissing her negligence action against defendant, Jefferson

County R-1 School District (the District). She also appeals the

court’s post-dismissal order granting the District’s request for

attorney fees. We affirm the judgment and the order.

I. Background

¶2 The following facts are taken from Garcia’s complaint.

¶3 Garcia fell and injured herself when she tripped over a

two-inch protruding steel stanchion embedded in the floor of a

middle school gym’s doorway in the District. The purpose of a

stanchion is to secure a door mullion. A mullion is a vertical steel

bar in the middle of a double doorway, which allows the double

doors to be locked or secured. It is designed to be removable,

however, which permits use of the entire width of the doorway.

¶4 The mullion had been removed from the doorway of the gym to

allow students to move large instruments into the gym in

preparation for a band concert that day. The District failed to

replace the mullion before arrival of guests for the band

performance. Garcia tripped on the stanchion and was injured.

1 ¶5 Garcia sued the District under the Colorado Premises Liability

Act, § 13-21-115, C.R.S. 2025, and in the alternative brought a

negligence claim. The District moved to dismiss the complaint for

lack of subject matter jurisdiction under C.R.C.P. 12(b)(1),

contending that it was immune from liability under the Colorado

Governmental Immunity Act (CGIA), §§ 24-10-101 to -120, C.R.S.

2025. Garcia sought discovery on the jurisdictional issue. The

district court denied Garcia’s request for discovery and granted the

District’s motion to dismiss.

¶6 The District moved for an award of $23,023.25 in attorney fees

under section 13-17-201, C.R.S. 2025, which the court awarded.

II. Motion to Dismiss

¶7 Garcia contends that the district court erred by dismissing her

complaint. We discern no error.

A. Standard of Review and Applicable Law

¶8 The applicability of immunity under the CGIA is an issue of

subject matter jurisdiction to be determined by the district court in

accordance with C.R.C.P. 12(b)(1). Fogg v. Macaluso, 892 P.2d 271,

276 (Colo. 1995); Young v. Jefferson Cnty. Sheriff, 2012 COA 185,

¶ 7. “When the alleged jurisdictional facts are in dispute, the trial

2 court should conduct an evidentiary hearing before ruling on the

jurisdictional issue.” Padilla v. Sch. Dist. No. 1, 25 P.3d 1176, 1180

(Colo. 2001). But where, as here, the relevant facts are undisputed,

the issue of governmental immunity is one of law, and the district

court may rule on the jurisdictional issue without an evidentiary

hearing.1 Id. In such a case, we review the district court’s

jurisdictional ruling de novo. Tidwell v. City & County of Denver, 83

P.3d 75, 81 (Colo. 2003).

¶9 A plaintiff bears the burden of showing that jurisdiction exists,

so, in the context of the CGIA, it must demonstrate that immunity

has been waived. Smokebrush Found. v. City of Colorado Springs,

1 Although Garcia requested discovery on factual issues such as

whether doors were locked, when guests and students arrived, and when the mullion was removed, she did not request discovery on the design of the mullion-stanchion mechanism. In fact, she concedes that the mullion was designed to be removable. See Herrera v. City & County of Denver, 221 P.3d 423, 428 (Colo. App. 2009) (concluding that the trial court was not required to hold an evidentiary hearing to determine whether the city and county was immune under the CGIA from suit arising from a collision between a motorist’s vehicle and a snowplow, inasmuch as the city and county did not contend on appeal that a factual question existed as to whether the snowplow met the statutory definition of “motor vehicle,” and the issue of whether the snowplow could be a “motor vehicle” was one of law). Thus, no evidentiary hearing was required regarding the design of the door.

3 2018 CO 10, ¶ 21. Because the CGIA “derogates Colorado’s

common law,” we strictly construe its immunity provisions, but we

broadly construe its waiver provisions “in the interest of

compensating victims of governmental negligence.” Id. at ¶ 22.

¶ 10 Further, to the extent our review depends on an interpretation

of the CGIA, we review such questions de novo. See Springer v. City

& County of Denver, 13 P.3d 794, 798-99 (Colo. 2000). Our primary

purpose when construing a statute is to ascertain and give effect to

the General Assembly’s intent. Id. at 799. We look first to the

statute’s language, giving words and phrases their plain and

ordinary meanings. Id. If the statute is unambiguous, we need not

conduct any further statutory analysis. Id.

¶ 11 Under the CGIA, public entities are generally immune from

liability in “all claims for injury that lie in tort or could lie in tort.”

§ 24-10-106(1), C.R.S. 2025. However, sovereign immunity is

waived in actions for injuries that resulted from “[a] dangerous

condition of any public building.” § 24-10-106(1)(c). A dangerous

condition is

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

4 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.

§ 24-10-103(1.3), C.R.S. 2025. The supreme court has interpreted

this definition as creating a four-part test. St. Vrain Valley Sch.

Dist. RE-1J v. Loveland, 2017 CO 54, ¶ 16 (citing Springer, 13 P.3d

at 799). A dangerous condition exists when a plaintiff establishes

that their injuries occurred because of (1) the physical condition of

the public facility or use thereof, (2) which constituted an

unreasonable risk to the health or safety of the public, (3) which

was known to exist or should have been known to exist in the

exercise of reasonable care, and (4) which was proximately caused

by the negligent act or omission of the public entity in constructing

or maintaining such facility. Id.

¶ 12 A dangerous condition “shall not exist solely because the

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