Jaimi J. Mostellar v. City of Colorado Springs, a Colorado municipality.

CourtSupreme Court of Colorado
DecidedApril 13, 2026
Docket24SC761
StatusPublished
Cited by1 cases

This text of Jaimi J. Mostellar v. City of Colorado Springs, a Colorado municipality. (Jaimi J. Mostellar v. City of Colorado Springs, a Colorado municipality.) 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
Jaimi J. Mostellar v. City of Colorado Springs, a Colorado municipality., (Colo. 2026).

Opinion

2026 CO 22

Jaimi J. Mostellar, Petitioner
v.
City of Colorado Springs, a Colorado municipality. Respondent

No. 24SC761

Supreme Court of Colorado, En Banc

April 13, 2026


          Certiorari to the Colorado Court of Appeals Court of Appeals Case No. 23CA1908

         Judgment Affirmed

          Attorneys for Petitioner: Kane Law Firm, P.C. Mark H. Kane Colorado Springs, Colorado

          Attorneys for Respondent: Marc Smith, Acting City Attorney W. Erik Lamphere, Division Chief Colorado Springs, Colorado

          Attorneys for Amicus Curiae Colorado Municipal League: Robert D. Sheesley Rachel Bender Denver, Colorado

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          JUSTICE GABRIEL delivered the Opinion of the Court, in which CHIEF JUSTICE MARQUEZ, JUSTICE BOATRIGHT, JUSTICE HOOD, JUSTICE SAMOUR, JUSTICE BERKENKOTTER, and JUSTICE BLANCO joined.

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          OPINION

          GABRIEL JUSTICE

         ¶1 We granted certiorari to consider whether (1) the court of appeals division below erred in reversing the district court's order denying the City of Colorado Springs' motion to dismiss, in which the district court had found that the deadline to provide notice under the Colorado Governmental Immunity Act ("CGIA") did not begin to run until the City of Manitou Springs informed Jaimi J. Mostellar of the intergovernmental agreement that made Colorado Springs potentially liable for her accident; and (2) the CGIA should require strict compliance when such compliance is impossible based on one public entity's failure to inform the claimant of the potential liability of another public entity.

         ¶2 Addressing the second issue first, we conclude that this case does not implicate a scenario in which strict compliance with the CGIA was impossible or a defendant prevented strict compliance by misleading a plaintiff. In this case, Colorado Springs, which was the entity entitled to notice, did nothing to inhibit Mostellar's compliance with the CGIA. Accordingly, strict compliance with the CGIA's plain terms was required.

         ¶3 Having thus decided, we turn to the first issue on which we granted certiorari, and we conclude that under section 24-10-109(1), C.R.S. (2025), of the CGIA, the notice period began to run on August 26, 2021, the date on which Mostellar was injured, not on the date that Manitou Springs informed her of the

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intergovernmental agreement. Accordingly, Mostellar's notice of claim was untimely, and the division correctly determined that her claim must be dismissed.

         ¶4 We therefore affirm the division's judgment.

         I. Facts and Procedural History

         ¶5 Mostellar alleged that she was injured on a public sidewalk in Manitou Springs on August 26, 2021, when she tripped and fell over the base of an old bus stop sign that had been removed. She then provided Manitou Springs with timely notice of her injury pursuant to section 24-10-109(1) of the CGIA, which requires "person[s] claiming to have suffered an injury by a public entity" to file written notice with that public entity "within one hundred eighty-two days after the date of the discovery of the injury."

         ¶6 Over the ensuing months, Manitou Springs never indicated that it was not the real party in interest. In April 2023, however, over a year and a half after Mostellar's fall, Manitou Springs informed Mostellar, for the first time, that pursuant to an intergovernmental agreement between it and Colorado Springs, Colorado Springs was responsible for the condition of the sign (and, thus, the condition of the sidewalk on which Mostellar was injured).

         ¶7 Forty days later, on May 30, 2023, Mostellar provided Colorado Springs with notice under the CGIA. By that point, however (and even by the day on

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which Mostellar was advised of Colorado Springs' involvement), section 24-10-109(1)'s 182-day notice period had long passed.

         ¶8 Mostellar thereafter brought an action against both Colorado Springs and Manitou Springs, asserting claims for premises liability and negligence, stemming from the existence of a "significant trip hazard" on the sidewalk on which Mostellar had fallen. Colorado Springs responded by moving to dismiss on the ground that Mostellar had not provided it with timely notice under the CGIA. In support of this contention, Colorado Springs argued, among other things, that equitable defenses, such as tolling, did not overcome the CGIA's 182-day notice period and that Mostellar's failure to comply with that statutory deadline required the court to dismiss her complaint for lack of subject matter jurisdiction.

         ¶9 Mostellar responded that her notice to Colorado Springs was timely under the CGIA, because, in her view, "the statute of limitations with respect to Defendant Colorado Springs did not begin to run until Plaintiff knew of the city's potential liability as the real party in interest for the cause of her injury." In support of this argument, Mostellar asserted that under our decision in Finnie v. Jefferson County School District R-1, 79 P.3d 1253, 1256-58 (Colo. 2003), determinations of compliance with section 24-10-109(1) should consider whether the purposes of the statute—namely, to allow public entities to investigate and remedy dangerous conditions promptly, to foster prompt settlement of

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meritorious claims, to make necessary arrangements to cover potential liability, and to prepare to defend themselves—were satisfied. She further contended that when a public entity has engaged with a plaintiff in a way that thwarts those aims, service on that entity is not necessary and principles of agency and equity should apply. And she argued that a claimant like her must be afforded a reasonable opportunity to discover the basic and material facts underlying a claim before having to provide the statutorily required notice. This was particularly true here, given that she asserts that she had no means of discovering the intergovernmental agreement other than through Manitou Springs and Manitou Springs had not advised her of that agreement until approximately a year and a half after Mostellar had provided it with notice. Mostellar thus contended that her claim was "within the 182 day requirement upon discovering the basic and material facts concerning Colorado Springs' responsibility."

         ¶10 The district court ultimately denied Colorado Springs' motion to dismiss. Although the court believed that Finnie was distinguishable because it implicated section 24-10-109(3), rather than section 24-10-109(1), of the CGIA, the court agreed with Mostellar that under State v. Young, 665 P.2d 108, 109-11 (Colo. 1983), the CGIA's notice period did not begin to run until she learned not only of her injury but also of who caused it.

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Jaimi J. Mostellar v. City of Colorado Springs, a Colorado municipality., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jaimi-j-mostellar-v-city-of-colorado-springs-a-colorado-municipality-colo-2026.