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Cherokee Metropolitan District v. Meridian Service Metropolitan District

Citations: 266 P.3d 401; 2011 WL 6147620Docket: Nos. 10SA379, 11SA197

Court: Supreme Court of Colorado; December 11, 2011; Colorado; State Supreme Court

Narrative Opinion Summary

The case involves two direct appeals from water court proceedings concerning the denial of intervention and the grant of declaratory relief in a water rights dispute. The primary parties include governmental entities responsible for water management and a groundwater management district. The proceedings originated from a conflict over water rights and the interpretation of a 1999 settlement requiring aquifer recharge by returning wastewater. An intergovernmental agreement in 2003 established a joint wastewater treatment facility, and a subsequent replacement plan application sought credit for these returns. When the groundwater district objected, seeking declaratory judgment and an injunction, the water court initially denied Meridian's motion to intervene, reasoning that its interests were adequately represented by Cherokee. However, the Supreme Court reversed this decision, asserting Meridian's right to intervene under Rule 24(a) due to its vested water rights and interests in return flows. The Court vacated the declaratory judgment, emphasizing that Meridian's interests were not adequately represented and remanded the case for further proceedings. The decision underscores the liberal interpretation of intervention rights to ensure comprehensive participation in matters affecting significant water rights.

Legal Issues Addressed

Adequate Representation in Intervention

Application: The Court emphasized that Meridian's interests were not adequately represented by Cherokee, necessitating intervention to protect its specific water rights and interests.

Reasoning: Meridian's interests are not adequately represented by the existing parties, fitting into the third category of representation analysis.

Declaratory Judgment and Replacement Plan Application

Application: The Court vacated the declaratory judgment order that restricted Cherokee's claims on wastewater returns, recognizing that it impacted Meridian's rights under the Replacement Plan Application.

Reasoning: The court reverses the water court's denial of Meridian's motion to intervene, vacates the declaratory judgment order granted to UBS, and mandates the reopening of proceedings to allow Meridian to participate.

Intervention as of Right under C.R.C.P. 24(a)

Application: The Court determined that Meridian Service Metropolitan District had a right to intervene in the declaratory judgment action due to its vested interest in the water rights affected by the proceedings.

Reasoning: The Court concluded that Meridian had a right to intervene under C.R.C.P. 24(a), reversing the water court's denial of Meridian's motion, vacating the declaratory relief granted, and remanding for further proceedings.

Liberal Interpretation of Intervention Rights

Application: The Court applied a liberal standard to intervention rights to ensure all parties with a potential stake in the outcome could participate, highlighting the importance of including all related issues for efficient resolution.

Reasoning: The analysis emphasized a liberal interpretation of intervention rights to include all concerned parties and issues related to the same transaction for efficient resolution.