Supreme Court of Colorado
for a Safe and Independent Woodmen Hills v. Campaign Integrity Watchdog, LLC
September 9, 20192019 CO 76
Summary
The court held that the one-year limitations period for a private campaign-finance enforcement action begins when the violation adjudicated and penalized in the administrative decision occurred, not when a later continuing violation allegedly ended. Because the enforcement action was filed more than one year after the latest date reflected in the administrative decision, it was time-barred. The court also held that the constitutional prevailing-party fee provision is self-executing and cannot be limited by the statutory restriction applicable to pro se parties, so the prevailing petitioners were entitled to reasonable fees.