Colorado Ethics Watch - Ethics Roundup 2010

8/6/2019 Colorado Ethics Watch - Ethics Roundup 2010

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ColoradosEthics Agenda

2010


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Introduction

In recent years, Colorados ethics agenda has been at the top of everyones mind. FromAmendment 27, which put campaign finance disclosure requirements and contributionlimits into the state constitution in 2002, to HB1370, which strengthened ballot measure

disclosure requirements in 2010, Coloradans have demanded high standards for ethicsand transparency from public officials and groups that try to affect election outcomes.Founded in 2006, Colorado Ethics Watchs core mission is to ensure that these highstandards are enforced through legal actions and increased public awareness of ethics andtransparency issues.

In 2010, Colorado legislators and other public officials made progress toward the goal ofeliminating corruption, increasing transparency and closing loopholes that might allowindividuals or businesses to abuse both the system and the public trust. As beneficial asmany of these reforms were, there is more to be done. In 2011, the Colorado legislaturemust take a hard look at unresolved issues and commit to fixing these problems before

they snowball into business as usual.

In its 5th year of ensuring accountability and promoting transparency, Colorado EthicsWatch has identified six legislative and regulatory changes that should be addressed in2011. This yearsEthics Roundup goes into detail about those six issues, explaining thesituations that illustrate each problem and the needed legal reforms to address them.

From imposing criminal penalties for bribery of a candidate to regulating privatefundraising by government officials, each of these six issues highlights people andproblems similar to those featured in the previous two editions of theEthics Roundup.This year, however, Ethics Watch is doing things a little differently. Rather than justfocusing on the problems that arose in 2010, Ethics Roundup 2010 identifies the worstbehavior, analyzes what underlying issues enable this behavior, and concludes that aspecific set of legislative and regulatory fixes would be most effective in ensuring thesemisdeeds are not allowed to happen again. These six fixes should be Colorados EthicsAgenda for 2011.

The six specific reforms advocated by Ethics Watch are:

1. Close Loopholes in Disclosure Laws for Ballot Initiative Elections2. Impose Criminal Penalties for Bribery of a Candidate3. Strengthen Ethics Rules for Unpaid Members of State Boards and Commissions4. Improve Collection of Campaign Finance Penalties5. Regulate Private Fundraising By Government Officials6. Reform the Independent Ethics Commissions Investigation and Hearing Process

Many people were in the news and in court, drawing our attention and earning notorietyin this report. These include Douglas Bruce for his efforts to avoid having to testify in acampaign finance case, unidentified supporters of Tom Tancredo who allegedly offeredbribes to get Dan Maes to drop out of the race for governor, and State Board of Education

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member Peggy Littleton for doing business with charter schools under her jurisdiction.The Pinnacol Assurance board, Colorado Independent Automotive Dealers PoliticalCommittee and the Colorado League of Taxpayers are also highlighted in this report.

Colorado Ethics Watch is dedicated to using every legal tool at our disposal to ensure that

Colorado government is ethical and transparent. From our vantage point, however, it isevident that in many respects the legal tools available dont match up to the challengepresented by groups and individuals who skirt ethical standards. We hope that this yearsEthics Roundup will serve as a guide for legal reform to make sure Colorado will enjoyclean and transparent government for years to come.

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Close Loopholes in Disclosure Laws for Ballot Initiative Elections

Colorado's ballot initiative system was severely abused this year, with four of thesix voter-initiated measures on the statewide ballot making it to Election Day withoutdisclosure of who paid for the printing of petitions or the collection of signatures to

qualify those measures for the ballot.

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Reform already in place for 2011 should curbsome abuses, but the legislature should strengthen enforcement of subpoenas incampaign finance cases and require non-profits that independently spend on ballot

issue campaigns to disclose their spending.

In theory, this should be the last year Colorado sees shenanigans like those fromthe proponents of Amendments 60 and 61 and Proposition 101, who denied knowing howa petition drive to get those measures on the ballot was funded.

2A ballot disclosure law

sponsored by Rep. Lois Court (D-Denver), taking effect January 1, will require issuecommittee registration no later than when 200 petition sections are printed. 3 This shouldmake it harder for ballot issue proponents to pretend that they managed to qualify an

issue for the ballot without reaching the $200 reporting threshold. But the problems inColorado's system went beyond proponents' failure or refusal to disclose how they paid toget an initiative on the ballot.

Douglas Bruce revealed a gaping hole in campaign finance enforcement when heresisted having to testify in the first of two lawsuits filed over Amendments 60 and 61and Proposition 101. Mr. Bruce evidently understood that administrative law judges incampaign finance cases have no power to enforce their own subpoenas and gamed thesystem for months, forcing the Attorney General to file a new lawsuit as part of acumbersomeprocess to have the subpoenas to Mr. Bruce enforced by a Denver DistrictCourt judge.4 Mr. Bruces antics led to calls for reform from both the Colorado SpringsGazette

5and The Denver Post.

6Legislators should take the advice given by these two

editorial boards seriously and give judges in campaign finance cases more authority toenforce their own subpoenas.

Another issue is that independent groups are permitted to spend freely on ballotinitiatives without disclosure, so long as the group does not have a "major purpose" of

1 Joe Hanel, Ballot funding remains mystery, The Durango Herald, October 29, 2010;Eileen Welsome, Ballot measures sponsors appeal order to divulge financial backers,The Gazette (Colorado Springs), July 27, 2010.2 Eileen Welsome, Hearing lifts veil on campaign for disputed measures, The Gazette(Colorado Springs), May 26, 2010.3 2010 Colo. Sess. Laws ch. 270.4 Wayne Laugesen, OUR VIEW: Why Douglas Bruce ignored subpoenas, The Gazette(Colorado Springs), June 9, 2010; Armando Montao, Suthers to file contempt motionagainst Douglas Bruce, Mr. X, The Colorado Independent, June 11, 2010.5 Laugesen, The Gazette, June 9, 2010.6 Better tools to track initiatives, The Denver Post, October 21, 2010.

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influencing elections.7 This year, the Independence Institute appears to have disclosed itsspending in support of Amendment 63, the proposed constitutional amendment on healthcare, as in-kind contributions to the official pro-63 committee.

8Another non-profit

group, the Pretrial Justice Institute, operated a website in opposition to Proposition 1029but was not legally required to register as an issue committee because of the "major

purpose" rule.

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These organizations deserve credit for voluntarily revealing theirinvolvement in these campaigns, but voters should not have to rely on the good faith ofoutside groups to find out who is financing a campaign for or against an initiative. Thelegislature should expand the independent expenditure disclosure law passed in 2010after the Supreme Courts Citizens Uniteddecision11 to require disclosures by individualsand groups other than issue committees that spend to support or oppose ballot initiatives.

7 Colo. Const. art. XXVIII, 2(10); Campaign and Political Finance Rule 1.7(b), 8C.C.R. 1505-6.8 Health Care Choice for Colorado, Report of Contributions and Expenditures(Amended), July 19, 2010.9 http://www.votenoto102.org/(visited November 8, 2010).10 See Colo. Const. art. XXVIII, 2(10)(a)(I).11 2010 Colo. Sess. Laws ch. 269.

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Impose Criminal Penalties for Bribery of a Candidate

Colorados Fair Campaign Practices Act (FCPA) provides that [n]o person shalloffer or give any candidate or candidate committee any money or any other thing of valuefor the purpose of encouraging the withdrawal of the candidate's candidacy.12 This law

was tested late in this years gubernatorial race, when the campaign of Republicancandidate Dan Maes stood by allegations made by Joseph Harrington, a Maes supporterfrom Douglas County. Mr. Harrington alleged that supporters of Tom Tancredo werediscussing a potential offer to Mr. Maes of a bunch of money in a 501(c)(4) non-profitfoundation, in exchange for getting out of the race - with the money coming from someun-named wealthy donor.13

Tancredo supporter Ross Kaminsky denied the specifics of Mr. Harringtonsallegations, but confirmed that he discussed with Mr. Harrington and an unidentified thirdparty the idea of some kind of commission, not a government paid job, but somethingthat would be funded with private money as an incentive to exit the race.

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After the Tancredo campaign denied any knowledge of any scheme to bribe Mr.Maes to withdraw, Mr. Harrington posted on his Facebook page a video tape of himselfplaying a voice mail message purportedly from Bay Buchanan, Mr. Tancredos campaignmanager.15 On the tape, the voice identified as Ms. Buchanan mentioned poll resultsshowing that Mr. Tancredo was gaining on John Hickenlooper, then said Hes got tofind somebody that he trusts to talk to us, somebody who he trusts their word and thatthe time is absolutely now. While the voice on the tape did not mention any financialoffer in order to induce Mr. Maes to drop out of the race, that would seem to be impliedbecause there would be no need to find somebody that he trusts to talk to us if the pleawere simply that Mr. Maes should drop out due to his sagging poll numbers.

Whether Mr. Maes ever received an illegal offer to drop out of the election

may never be known, but the episode focused attention on the penalties or lack

thereof for bribing a candidate to drop out of a race. The statute itself does notprescribe a specific penalty for a violation.16 Amendment 27, which revised Coloradoscampaign finance laws in 2002, specifically included this statute in the list of statutes thatcan be privately enforced through a complaint filed with the Secretary of State and heardbefore an administrative law judge.17 Amendment 27 did not, however, specify a penaltyfor violation of the candidate bribery statute. According to a 2009 ruling of the Colorado

12 C.R.S. 1-45-115.13

http://www.facebook.com/note.php?note_id=135454869837839&id=553868138&ref=mf, visited on October 28, 201014Lynn Bartels, Blogger: I never offered Maes money to quit the race, The Denver Post,October 19, 2010, http://www.denverpost.com/news/ci_16377771.15http://www.facebook.com/video/video.php?v=453813723138, visited on October 25,2010; Bartels, The Denver Post, October 19, 2010..16 C.R.S. 1-45-115.17 Colo. Const. art. XXVIII, 9(2)(a).

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Court of Appeals, the penalties prescribed in Amendment 27 only apply to violations ofcontribution and voluntary spending limits contained in the amendment itself and not tostatutory violations.

18The FCPAs general penalty provision, in turn, applies only to

those provisions of the FCPA that, unlike the ban on candidate bribery, are notspecifically mentioned in Amendment 27.19 Thus, civil penalties for violating the ban on

offering bribes to candidates to induce them to drop out are unclear at best.

The larger question is why this form of bribery would be treated as a civil matterunder the FCPA, instead of a crime. All other forms of bribery prohibited underColorado law carry criminal penalties. For example, offering money to a voter to inducehim or her to vote, or not to vote, or to vote a certain way is a misdemeanor crime.20Colorados criminal code makes it a misdemeanor to trade in public office, which isdefined as offering money to public or political party officials as a way to obtainappointment to a position or nomination as a candidate.21 Bribery of a public servant andfinancially rewarding a public official for past official action are both felony crimes.22There are also felony penalties for private sector bribery

23and sports bribery.

24Bribing a

duly nominated candidate to drop out of an election is at least as serious as these otherforms of bribery.

In view of the gravity of an effort to circumvent the political process byattempting to buy off a nominee for public office, civil penalties are not enough.Colorados ethics agenda needs to include felony criminal penalties for bribery of acandidate.

18 Sherritt v. Rocky Mountain Fire Dist., 205 P.3d 544, 546 (Colo. App. 2009).19 C.R.S. 1-45-111.5(1.5)(b).20 C.R.S. 1-13-720.21 C.R.S. 18-8-305.22 C.R.S. 18-8-302 and 303.23 C.R.S. 18-5-401.24 C.R.S. 18-5-403.

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Strengthen Ethics Rules for Unpaid Members of State Boards and Commissions

Ethical lapses by members of unpaid boards and commissions made headlines in2010. Three members of the state board that oversees Pinnacol Assurance, the stateworkers compensation authority, accompanied Pinnacol executives on a golf vacation to

Pebble Beach, California, apparently at Pinnacol expense.

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State Board of Educationmember Peggy Littleton was revealed to have earned large commissions as a real estatebroker working for charter school operators,26 even though as a member of the StateBoard of Education she would be involved in hearing and deciding a charter schoolsappeal of a school districts denial of one of her clients charter school applications.27

Both of these actions would be illegal if performed by a paid governmentemployee.

28The primary ethics law for unpaid members of boards and commissions,

however, prohibits only official acts that directly benefit businesses owned bycommission members.29

There are good reasons not to subject unpaid members of state boards andcommissions to the full range of regulations that apply to full-time governmentemployees. Nevertheless, it is not unreasonable to ask those board members to avoidaccepting gifts or entering into business deals with people whom they also regulate.The legislature should amend the ethics statute that applies to members of unpaid boardsand commissions to include these restrictions.

25 Arthur Kane and Tony Kovaleski, Lawmakers Outraged By Pinnacol Trip,TheDenverChannel.com, May 25, 2010.26 Pam Zubeck, Talking Out of School, Colorado Springs Independent, October 14,2010.27 C.R.S. 22-2-207(1)(t).28 Colo. Const. art. XXIX, 3(2); C.R.S. 24-18-108.29 C.R.S. 24-18-108.5.

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Improve Collection of Campaign Finance Penalties

At a time when the state cannot afford to squander a single resource, hundreds ofthousands of dollars remain uncollected for outstanding campaign finance penalties.Failure to collect penalties does more than deprive the state of revenue. Failure to collect

sends the message that there are no real consequences for defying campaign finance laws.

Campaign finance laws in Colorado are primarily enforced through civil penaltiespayable to the state.30 Penalties can arise from simple violations such as missed filings ormore egregious violations like making or accepting unlawful contributions. Late filingpenalties are normally imposed by the Secretary of State and accrue at the rate of $50 perday unless the Secretary grants a request to reduce the penalty.31 Other penalties aretypically imposed through the private-party complaint process in the Office ofAdministrative Courts.32 Penalties for violations of contribution and spending limits areset at at least double and up to five times the amount contributed, received, or spent.33

Some of the largest accrued fines have been imposed on committees thatrepeatedly miss deadlines over the course of years without requesting a waiver orreduction of the penalty. One group, the Colorado Independent Automotive DealersPolitical Committee, amassed $528,500 in fines over a period of three years. 34According to the Secretary of States TRACER campaign finance disclosure website, ttop ten delinquent committees accrued fines totaling $457,900 during the 2010 electioncycle.

he

eaguey

35 In other cases, committees that have been assessed fines by an administrativelaw judge simply cease operations and fail to pay, as in the case of the Colorado Lof Taxpayers, fined $7150 for disclosure violations in the election for Garfield CountCommissioners in 2008.

36

One reason penalties are nearly impossible to collect is that no personal

liability attaches to the debts of most committees. An issue or political action

committee can avoid collectors by becoming inactive, simply dissolving, or by

ignoring the debt while continuing business as usual.

30 Colo. Const. art. XXVIII, 10.31 Colo. Const. art. XXVIII, 10(2).32 See Colo. Const. art. XXVIII, 9(2).33 Colo. Const. art. XXVIII, 10(1).34 John Ingold, Half-million-dollar fine becomes issue in secretary of state race, TheDenver Post, October 12, 2010.35 http://tracer.sos.colorado.gov/PublicSite/QuickStats.aspx, visited on November 10,2010. The top ten delinquent filers were Colorado Reform Party, Advocates for BetterRepresentation, James R. Phillips, Women of Color United, Olds2008, Jose G. Silva forColorado, Colorado Independent Auto Dealers Political Committee, Committee to ElectJeff Shaw, Colorado Right-to-Work Committee, and Colorado Federation of RepublicanWomen Small Donor Committee.36 David O. Williams, GOP operative Shires still has not paid fine in 2008 GarfieldCounty election, The Colorado Independent, October 8, 2010.

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By law, candidates are personally liable for fines assessed against their candidate

committees.37

There is no parallel provision making anyone personally liable for finesassessed against issue committees, political committees, or other committees. Imposingpersonal liability on registered agents for delinquent committees other than candidate

committees is one alternative the legislature may wish to consider to improve bothcompliance and fine collection.38

Another possible solution would be to empower the Secretary of State to closecommittees and prohibit them from operating if the committees miss several consecutivereports or fail to pay outstanding fines. Under existing rules, the Secretary of State canadministratively close a committee if it fails to file reports for two years.39 Authorizingdissolution after a committee has missed three or four consecutive reports or incurs asignificant amount of unpaid fines would improve both compliance and fine collection.

37 Colo. Const. art. XXVIII, 10(1).38 David O. Williams, Secretary of State hobbled in battle against clean-electionsviolators, The Colorado Independent, December 4, 2009.39 Campaign and Political Finance Rule 2.10, 8 C.C.R. 1505-6.

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Regulate Private Fundraising by Government Officials

As state tax revenues fail to keep pace with Colorados growth, public officialsare increasingly turning to private contributions as a source of revenue for publicactivities. Questions of transparency around private grants should be answered by a new

state law, but ethics questions around fundraising by state officials remain. To avoidconflicts of interest, the legislature should enact ethics rules regulating fundraising bypublic officials from private individuals and corporations under their jurisdiction.

According to the State Taxpayer Accountability Report (STAR), OperatingGrants and Contributions rose substantially during Fiscal Year 2008-09 (the most recentyear for which data is available), largely making up for decreasing tax revenue.40 TheOperating Grants and Contributions category includes federal as well as private grants,making it impossible to determine the extent to which private funds are being raised bythe state. A new reporting requirement enacted during the 2010 legislative session shouldimprove transparency of both federal and private grants and allow Coloradans to

understand the extent to which private contributions are funding governmentoperations.41 In the City and County of Denver, disclosure of private grants has beenrequired since 2007.42 Denver disclosure reports reviewed by Ethics Watch revealsignificant grants from corporations such as Pepsi Cola Company, Wal Mart, and Oracle,as well as several grants from non-profit organizations and donations from individuals.

As Colorados revenue crisis continues, we must expect government to keeplooking to private grants as a source of funds for critical operations. Ethical concernsmay arise when public officials attempt to raise funds for government operations fromcorporations and wealthy individuals whom they regulate. In a recent non-bindingadvisory opinion, the Independent Ethics Commission (IEC) said that fundraising bylegislators on behalf of quasi-governmental bodies may carry the actuality or appearanceof impropriety when that fundraising includes solicitations to lobbyists and corporationsand carries the appearance of a climate in which interested parties donate . . . inexchange for support of legislation.

43

The IECs concerns are well-founded, but legislators and executive branch

officials deserve clear, binding guidance as to the ethical restrictions around

fundraising from private parties on behalf of governmental and quasi-governmental

agencies.44 The legislature, with advice and guidance from the IEC, should craftstatutory restrictions on fundraising by public officials. For example, legislators shouldbe prohibited from fundraising from corporations who have, or are likely to haveinterests, in matters before committees of which the legislator is a member. Executive

40 State Taxpayer Accountability Report FY 2008-09 at p. 2.41 House Bill 10-1178, codifed as C.R.S. 24-73-1301 et seq.42 City and County of Denver Exec. Order 134 (Dec. 20, 2007).43 Independent Ethics Commission Advisory Opinion 10-14,Acceptance of a Luncheonfrom a Political Subdivision, September 16, 2010.44 See Colo. Const. art. XXIX, 1.

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branch officials should be prohibited from fundraising from persons actively seekinggovernment contracts or positions.45

45 Independent Ethics Commission Advisory Opinion 10-18, Organization and Fundingof Gubernatorial Transition, November 5, 2010.

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Reform the Independent Ethics Commissions Investigation and Hearing Process

An overhaul of the Independent Ethics Commissions (IEC) complaint process islong overdue a fact the Commissioners recognize. As currently structured, the processfor submitting complaints to the IEC regarding potential ethics violations by public

officials is ineffectual, overly litigious, and unduly burdensome on the person requestingan investigation.

According to the constitutional mandate that governs it, the IEC bears ultimateresponsibility for investigating and hearing non-frivolous complaints:

Any person may file a written complaint with the independent ethicscommission asking whether a public officer, member of the generalassembly, local government official, or government employee has failed tocomply with this article or any other standards of conduct or reportingrequirements as provided by law within the preceding twelve months.

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The state constitution also requires the IEC to conduct an investigation, hold ahearing, and render findings on each non-frivolous complaint pursuant to written rulesadopted by the commission.47 To fulfill its duty to determine whether an ethicsviolation has occurred, commissioners have the power to subpoena documents and tosubpoena witnesses to make statements and produce documents.48

The IECs approach to its responsibility to investigate has improved over thecourse of the three non-frivolous complaints that have proceeded to a final decision, butstill falls short of fulfilling its constitutional mandate. In its first non-frivolous case, theIEC refused to conduct any investigation beyond the minimal review required todetermine that the complaint was not frivolous.

49The IEC took this position even though

the language of the state constitution makes it clear that the IECs duty to investigate istriggered only afterthe IEC has determined whether the complaint is non-frivolous.50 Inthe second non-frivolous complaint, the IEC did engage staff to investigate some factsand have those facts presented at the hearing, however, the IEC still required thecomplaining person, who was not represented by counsel, to act as a prosecutor at ahearing where the respondent was represented by a lawyer from the Larimer CountyAttorneys office.51 In the third case, on Complaint 10-01 against a legislator, the IECdismissed the complaint as groundless after the investigation revealed no evidence that anethics violation occurred.52 While the complaining party did not dispute the absence of

46Colo. Const. art. XXIX, 5(3)(a).47Id. 5(3)(c).48Colo. Const. art. XXIX, 5(4).49 Procedural Determination,In the Matter of Mike Coffman (IEC Complaint 08-01),November 3, 2008.50Colo. Const. art. XXIX, 5(3)(c).51Summary of Final Action, Fry v. Burns (IEC Complaint 09-08), April 19, 2010.52Summary of Final Action, ODell v. Morse, IEC Complaint 10-01, May 26, 2010.

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evidence, the IECs dismissal of the complaint without the type of hearing prescribed inthe IECs own rules seems a clear violation of the requirement that the IEC hold ahearing on each non-frvolous complaint.

53 The IEC should change its rules to

recognize the practical reality that not every non-frivolous complaint should result

in a full-blown trial. Its rules should change to authorize the more flexible procedure

followed in the third case.

The IEC should also take control of the investigation and hearing process. Itcurrently advises potential complaining parties that the person filing a complaint has theburden of proving the allegations set forth in the complaint. 54 This advice is contrary tothe constitutional requirement that the IEC conduct an investigation, hold a publichearing, and render findings on each non-frivolous complaint.55 Adversarial hearingsbefore the IEC have been unnecessarily time-consuming and contentious because the IEChas not exercised control over the process that precedes the hearing. In addition, theprospect of having to act as a prosecuting attorney has undoubtedly deterred persons withknowledge of possible ethics violations from coming forward to the IEC.

To reform the system, the IEC should start by recognizing that the stateconstitution does not require the IEC to conduct a trial or any similar adversarial process;it merely requires that the IEC conduct a public hearing. 56 The IEC should also engageits staff to have primary responsibility for investigating complaints. Once a complaint issubmitted to the IEC asking whether a violation has occurred, the Commissioners andtheir staff must preliminarily determine if the complaint is frivolous. If non-frivolous, itis the IECs responsibility to conduct an investigation of the facts alleged. In doing so,commissioners should exercise their subpoena powers to take statements and obtaindocuments that would support proposed findings to be contained in a report to besubmitted by the staff to the IEC.

The IEC should reconsider what type of public hearing it will conduct whendetermining complaints and revise its rules accordingly. The IEC should resolvecomplaints based on its own investigation at a duly noticed public hearing during whichthe parties have an opportunity to object to proposed factual conclusions of IEC staff whoinvestigate the complaint. At such a hearing, a party could present evidence on disputedissues or simply be heard on the proper application of ethics standards to the establishedfacts. The Commissioners (not opposing attorneys) should ask questions of any witnessesa party may wish to present to question the findings of the investigation report. Ethicscommittees of the state legislature have conducted hearings in a similar manner, and stateand federal courts frequently utilize a special master proceeding under which a

53Colo. Const. art. XXIX, 5(3)(a).54Colorado Independent Ethics Commission, FYI 4 - Filing a Complaint with theIndependent Ethics Commission, http://www.colorado.gov/cs/Satellite/DPA-IEC/IEC/1251580838448, accessed on November 12, 2010.55Colo. Const. art. XXIX, 5(3)(c).56Id.

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masters report is presented to a judge, who resolves objections to the report from theparties at a hearing.57

The IECs dismissal of Complaint 10-01 was a step in the direction of thisprocedure the IEC dismissed the complaint at a public meeting after its investigation

revealed a complete lack of evidence suggesting an ethics violation by the respondent.

58

Under revised rules, Complaint 10-01 could have been resolved in a short public hearingduring which staff presented the results of the investigation and the IEC could havedismissed the complaint when the complaining party did not object or present anyevidence to contradict the reports proposed findings.

Finally, the IECs rules regarding penalties and sanctions merely state that it hasauthority to impose penalties as provided by law.

59The rules and/or the statute

governing the IEC60 should be revised to describe more specifically its authority to issuecensures, monetary penalties when authorized by law,61 and/or injunctive relief.

57 F.R.C.P. 53; C.R.C.P. 53.58Summary of Final Action, ODell v. Morse, IEC Complaint 10-01, May 26, 2010.59IEC Rule of Procedure 9.A.60C.R.S. 24-18.5-101.61See Colo. Const. art. XXIX, 6.

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Colorado Ethics Watch - Ethics Roundup 2010

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