Town of Superior v. Board of County Commissioners of Jefferson County

CourtColorado Court of Appeals
DecidedMarch 12, 2026
Docket25CA0836
StatusUnpublished

This text of Town of Superior v. Board of County Commissioners of Jefferson County (Town of Superior v. Board of County Commissioners of 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
Town of Superior v. Board of County Commissioners of Jefferson County, (Colo. Ct. App. 2026).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY March 12, 2026

2026COA14

No. 25CA0836, Town of Superior v. Board of County Commissioners of Jefferson County — Constitutional Law — Federal Supremacy — Preemption; Remedies — Injunctive Relief

A division of the court of appeals holds that federal law

preempts a claim for injunctive relief requiring an airport to ban

certain aircraft operations to abate aircraft noise. Under City of

Burbank v. Lockheed Air Terminal Inc., 411 U.S. 624, 638 (1973),

state and local regulation of aircraft noise is preempted by federal

law. And although the proprietor of an airport retains authority to

impose certain noise restrictions in its role as airport proprietor, a

state court may not order it to do so because such an injunction

would constitute impermissible local control over aircraft noise. The division remands the case to the district court to

determine whether the plaintiffs’ request for an injunction to abate

lead emissions is preempted by the Clean Air Act, 42 U.S.C. § 7573. COLORADO COURT OF APPEALS 2026COA14

Court of Appeals No. 25CA0836 Boulder County District Court No. 24CV30221 Honorable Stephen E. Howard, Judge

Town of Superior, a municipal corporation of the State of Colorado, and the Board of County Commissioners of the County of Boulder, Colorado, a county government in the State of Colorado,

Plaintiffs-Appellants,

v.

The Board of County Commissioners of the County of Jefferson, Colorado, as successors in interest to the Jefferson County Airport Authority, and Erick Dahl, in his official capacity as Airport Director of the Rocky Mountain Metropolitan Airport,

Defendants-Appellees.

JUDGMENT AFFIRMED IN PART AND REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division VI Opinion by JUDGE SCHOCK Grove and Yun, JJ., concur

Announced March 12, 2026

Greenberg Traurig, LLP, John A. Wharton, Andrew D. Barr, Elliot Anderson, Denver, Colorado, for Plaintiffs-Appellants

Kaplan Kirsch LLP, W. Eric Pilsk, Steven L. Osit, Denver, Colorado, for Defendants-Appellees ¶1 Federal law generally preempts state and local regulation of

aircraft noise. See City of Burbank v. Lockheed Air Terminal Inc.,

411 U.S. 624, 638 (1973). But an airport proprietor retains the

authority to impose noise restrictions at its airport — even when the

proprietor is a governmental entity. See Arapahoe Cnty. Pub.

Airport Auth. v. Centennial Express Airlines, Inc., 956 P.2d 587, 595

(Colo. 1998). The question in this case is whether a state court,

consistent with principles of federal preemption, may order the

proprietor to exercise that authority. We conclude that it cannot.

¶2 Plaintiffs, the Town of Superior (Superior) and the Board of

County Commissioners of Boulder County, allege that certain

aircraft operations at the nearby Rocky Mountain Metropolitan

Airport (the Airport) cause excessive noise and hazardous lead

exposure for their residents. They sued defendants, the Board of

County Commissioners of Jefferson County and Erick Dahl, in his

official capacity as Airport Director of the Airport (collectively,

Jefferson County), under a public nuisance theory, requesting an

injunction requiring them to prohibit such operations. The district

court dismissed the action on grounds of federal preemption.

1 ¶3 We agree with the district court that plaintiffs’ request for an

injunction to abate aircraft noise is preempted by the pervasive

federal scheme of aviation noise regulation, as recognized in City of

Burbank. But City of Burbank does not resolve the pollution-based

component of plaintiffs’ claim. And the district court did not

address Jefferson County’s argument that the federal Clean Air Act,

42 U.S.C. § 7573, preempts a ban on aircraft operations to abate

lead emissions.

¶4 We therefore (1) affirm the order to the extent it dismissed

plaintiffs’ request for an injunction to abate aircraft noise;

(2) reverse the order to the extent it dismissed plaintiffs’ request for

an injunction to abate lead emissions; and (3) remand the case to

the district court for further consideration of whether the lead

emissions portion of plaintiffs’ claim is preempted by federal law.

I. Background

¶5 The Airport is located in, and owned and operated by,

Jefferson County. Superior is less than a mile away, primarily in

Boulder County. Aircraft departing the Airport from its primary

runways fly over Superior and Boulder County upon takeoff.

2 ¶6 Four flight schools operate at the Airport using piston engine

aircraft — a type of small plane that is generally used for flight

training or recreation. Unlike most other types of aircraft, piston

engine aircraft typically use fuel that contains lead.

¶7 A common flight training maneuver is called a “touch-and-go.”

In a touch-and-go operation, an aircraft lands and immediately

takes off again without stopping. The operation is often repeated

several times within a single flight. Because an aircraft gets closer

to the end of the runway in a touch-and-go than in a typical takeoff,

the aircraft flies over Superior at a lower altitude and lower speed

than it otherwise would. Plaintiffs allege that this results in

excessive noise and hazardous lead exposure for their residents.

¶8 Plaintiffs sued Jefferson County for causing a public nuisance,

seeking to enjoin touch-and-go operations by piston engine aircraft

at the Airport. Jefferson County moved to dismiss the complaint

under C.R.C.P. 12(b)(5) based on federal preemption. Citing City of

Burbank, 411 U.S. at 638, it argued that federal law preempts state

and local regulation of aircraft operations, noise levels, and

emissions. Plaintiffs responded that their requested injunction fell

under the “proprietor’s exception,” which they argued allows airport

3 proprietors to impose restrictions to abate a nuisance that a state

or local government could not impose pursuant to its police power.

¶9 The district court granted the motion to dismiss. It concluded

that federal law preempts any local or state limitation on aircraft

flight operations, including as to noise or pollution. And it ruled

that a court order enjoining touch-and-go operations would

constitute such a local regulation. Addressing plaintiffs’ argument

about Jefferson County’s proprietary rights, the court explained

that “the ability of [the district] court to issue an injunction is a

different issue than whether a proprietor can choose to limit noise

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