Marilyn Daniel v. City of Colorado Springs, a Colorado Municipal Corporation and Home Rule City

Summary

The court held that a public golf-course parking lot can qualify as a public facility under the Colorado Governmental Immunity Act's recreation-area waiver and that the parking lot was located in a recreation area. It adopted a three-step framework for identifying the relevant recreation area, determining the public entity's primary purpose, and deciding whether the facility lies within the area's boundaries. Because the record was insufficient to resolve the waiver's maintenance and dangerous-condition requirements, the court reversed and remanded. Justice Coats, joined by Justice Eid, concurred in the judgment but rejected the majority's framework and statutory interpretation.