Williams v. Libertarian Party of Colorado

Summary

The Colorado Supreme Court held that a claim under 42 U.S.C. § 1983 may not be brought in a proceeding under section 1-1-113 of the Colorado Election Code. The court overruled Brown v. Davidson to the extent it held otherwise and concluded that section 1-1-113 does not violate the Supremacy Clause because Colorado courts remain available to adjudicate § 1983 claims. The court reversed the court of appeals and remanded for further proceedings.

Holdings

1. A § 1983 claim may not be brought in a § 1-1-113 proceeding because § 1-1-113 is limited to allegations of a breach, neglect of duty, or other wrongful act under the Colorado Election Code.
2. C.R.S. § 1-1-113 does not run afoul of the Supremacy Clause because Colorado courts remain available to adjudicate § 1983 claims, including on an expedited basis when a preliminary injunction is sought.
3. Brown v. Davidson is overruled to the extent it holds that a § 1983 claim may be joined with a petition under C.R.S. § 1-1-113.

Questions Presented

1. Whether a claim under 42 U.S.C. § 1983 may be brought or joined in a proceeding under C.R.S. § 1-1-113.
2. Whether C.R.S. § 1-1-113's limitation to violations of the Colorado Election Code conflicts with the Supremacy Clause by excluding § 1983 claims.
3. Whether the respondents could obtain attorney's fees under 42 U.S.C. § 1988 for an unadjudicated § 1983 claim after prevailing on a related state constitutional claim.

Disposition

reversed_and_remanded