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

Summary

The court held that the expedited statutory proceeding is limited to claims alleging violations of duties or wrongful acts under the Colorado Election Code and therefore cannot include claims under 42 U.S.C. § 1983. It further held that this limitation does not violate the Supremacy Clause because Colorado courts remain available to adjudicate such federal claims, including on an expedited basis through ordinary procedures when appropriate. The court overruled contrary precedent, invalidated the related attorney-fee award, and remanded for further proceedings. Justice Gabriel, joined by Justice Hood, dissented, concluding that the statute permits joinder of related § 1983 claims and that separate litigation would undermine procedural efficiency and federal civil-rights enforcement.