Strumpf v. Dept of Corrections

CourtColorado Court of Appeals
DecidedMarch 5, 2026
Docket25CA1048
StatusUnpublished

This text of Strumpf v. Dept of Corrections (Strumpf v. Dept of Corrections) 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
Strumpf v. Dept of Corrections, (Colo. Ct. App. 2026).

Opinion

25CA1048 Strumpf v Dept of Corrections 03-05-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA1048 State Personnel Board No. 2025S48

Eric Strumpf,

Complainant-Appellant,

v.

Department of Corrections,

Respondent-Appellee,

and

State Personnel Board,

Appellee.

ORDER AFFIRMED

Division II Opinion by JUDGE FOX Kuhn and Sullivan, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced March 5, 2026

Eric Strumpf, Pro Se

Philip J. Weiser, Attorney General, Dominick D. Schumacher, Assistant Attorney General, Denver, Colorado, for Respondent-Appellee

No Appearance for Appellee ¶1 Eric Strumpf, a former employee of the Colorado Department of

Corrections (DOC), raised several claims before the Colorado State

Personnel Board (Board) challenging DOC’s failure to respond to his

requests for information about employment reinstatement options.

The Board dismissed his administrative complaint, and Strumpf

appeals. We affirm.

I. Background

¶2 While serving as DOC’s Director of Budget and Business

Operations, Strumpf took an extended leave and exhausted all his

paid leave, short term disability benefits, and benefits under state

and federal leave programs. In May 2024, DOC discharged him

pursuant to regulations promulgated by the Board (Board Rules)

that allow state agencies to administratively discharge employees

who exhaust all paid leave and are unable to return to work. See

Dep’t of Pers. & Admin. Rule 5-6, 4 Code Colo. Regs. 801-1. One

provision of the Board Rules provides that “[a] certified employee

who has been discharged under this rule and subsequently recovers

has reinstatement privileges.” Id. at Rule 5-6(C) (Board Rule 5-

6(C)). The notice effectuating Strumpf’s discharge indicated that he

1 was “entitled to be considered for reinstatement when [he] [was]

able to return to work.”

¶3 In late May 2024, Strumpf challenged his discharge. The Board

affirmed DOC’s decision, and Strumpf appealed. A different

division of this court recently reversed the Board’s order and

remanded the case with directions. See Strumpf v. Dep’t of Corr.,

(Colo. App. No. 25CA0543, Feb. 12, 2026) (not published pursuant

to C.A.R. 35(e)).

¶4 In December 2024, Strumpf sent several emails to DOC officials

requesting information about reinstatement. He said he wanted to

“explore reinstatement options” and asked for the procedure and

opportunities. DOC never responded, so in January 2025, he filed

a second complaint with the Board.1

¶5 Strumpf primarily took issue with DOC’s lack of response; he

did not explicitly request reinstatement and even wrote that he “no

longer believe[d] reinstatement is a healthy option.” He alleged that

DOC violated the Colorado Anti-Discrimination Act (CADA), §§ 24-

1 Although the Board calls this type of dispute an appeal, we refer

to Strumpf’s initial appeal as a complaint to avoid confusion with the multiple appeals discussed here.

2 34-401 to -408, C.R.S. 2025, on the basis of disability and because

“DOC’s refusal to respond to [his] reinstatement requests despite

[the] Board Rule directing [DOC] to grant reinstatement is clear

retaliation” for Strumpf’s challenge to his termination.

¶6 The Board referred the matter to an administrative law judge

(ALJ) who asked the parties to explain whether the Board had

jurisdiction over Strumpf’s complaint. After the parties responded,

the ALJ dismissed the complaint, concluding that the Board lacked

jurisdiction over his claims because Strumpf had not “applied for a

position or participated in a selection process” and because there

was no legal authority requiring automatic reinstatement upon

request. Strumpf appealed the ALJ’s order to the Board, and the

Board affirmed.2

¶7 Strumpf now appeals, arguing that the dismissal was improper,

the Board should have referred his complaint to the Colorado Civil

Rights Division (CCRD), and the Board’s transcript requirements

2 The Board apparently discussed Strumpf’s appeal of the ALJ’s

order at a May 20, 2025, meeting. However, a transcript of this meeting is not in the record before us.

3 violated his due process rights. He also asks us to provide direct

relief rather than remanding the case to the Board.

II. The Dismissal Order

¶8 Strumpf argues that the ALJ erred by concluding that the

Board lacked jurisdiction to review his complaint.3 And he argues

that DOC’s silence in response to his reinstatement inquiries

violated CADA. He also contends that DOC’s lack of response to his

reinstatement requests violated the Board Rules. We conclude that

the ALJ’s jurisdictional analysis was misguided. However, because

we conclude that Strumpf failed to allege discriminatory or

retaliatory conduct under CADA, we affirm. And to the extent that

Strumpf argued — separately from his CADA allegations — that

DOC violated the Board Rules, we conclude that the Board lacked

authority to consider those arguments.

A. Standard of Review

¶9 “We review an administrative agency’s decision for an abuse of

discretion” and will uphold the decision unless “the agency acted

3 Strumpf appeals the Board’s order affirming the ALJ’s order, but

we primarily refer to the ALJ’s order because the Board’s order affirmed without discussion or analysis.

4 arbitrarily or capriciously, made a decision that is unsupported by

the record, erroneously interpreted the law, or exceeded its

authority.” Gieck v. Off. of Info. Tech., 2020 COA 81, ¶ 12 (quoting

Colo. Dep’t of Hum. Servs. v. Maggard, 248 P.3d 708, 712 (Colo.

2011)). When there is a question of jurisdiction that does not

involve a factual dispute, we review the agency’s statutory

interpretation de novo. Id. at ¶¶ 12-13.

¶ 10 We affirm an agency’s decision if, viewed in a light most

favorable to the agency, there is a reasonable basis and substantial

evidence for its decision. Rags Over the Ark. River, Inc. v. Colo.

Parks & Wildlife Bd., 2015 COA 11M, ¶ 54. We also apply the

harmless error rule to administrative decisions and will not reverse

unless the appellant shows that he was prejudiced because the

agency’s error affected the outcome of the proceedings. Id. at ¶ 65.

B. The Board’s Jurisdiction or Authority

¶ 11 We first reject the ALJ’s and DOC’s suggestion that Strumpf’s

complaint was untimely because he filed it more than ten days after

his administrative discharge. The filing deadline for discrimination

complaints is “within ten days of the alleged practice,” § 24-50-

125.3, C.R.S. 2025, but the alleged practice here was not Strumpf’s

5 termination; it was DOC’s nonresponse. Moreover, it is difficult to

discern when a nonresponse occurs for purposes of this filing

deadline. See Ward v. Dep’t of Nat. Res., 216 P.3d 84, 92 (Colo.

App. 2008) (“[A]ny date when the [agency] engaged in the

discriminatory practice was too difficult to discern for purposes of”

section 24-50-125.3’s deadline.).

¶ 12 We next consider the ALJ’s conclusion that the Board lacked

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