In Re Ryan Frazier, Petitioner v. Wayne W. Williams

Summary

The court held that the expedited election proceeding is limited to claims alleging violations of duties or wrongful acts under the Colorado Election Code and cannot include a federal civil-rights claim. It concluded that this limitation does not violate the Supremacy Clause because Colorado courts remain available to adjudicate such federal claims, including through expedited injunctive relief, and therefore vacated the fee award and remanded. Justice Gabriel, joined by Justice Hood, dissented, arguing that the statute permits joinder of related federal claims and that requiring a separate action undermines procedural efficiency and federal civil-rights enforcement.